S. 143(3) : Assessment-Undisclosed income-Bogus purchases-Sales accepted-Statement in the course of search-Neither the statement was furnished nor an opportunity of cross examination was provided-Addition is held to be not justified. [S. 131, 133(6)]

S. 142(2A) : Inquiry before assessment-Special audit-Time limit-Assessment completed within two months from date of special Audit report-Held to be within limitation period. [S. 142(2C), 153]

S. 115JB : Book profit-Capital or revenue-Receipt of unutilised contribution from welfare trust-Not liable to tax while computing Book Profit. [S. 2(24), 40A(11)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Company whose audited financial data for previous year available in public domain not to be discarded merely because it has different financial year-Expenses on travel, boarding and lodging, etc. of its employees during outstation visits-Assessee should have marked up expenses by a profit-margin before making recoveries-Weighted average period of realization with respect to all invoices was only 20.52 days-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Net margin method-Adjustments to be restricted to international transactions and not to be applied to entire segment of manufacturing activity-Entitled to benefit of tolerance range of +5 Per Cent. [S. 92CA]

S. 92B : Transfer pricing-Associated enterprise-Performance guarantee-International Transactions-Transfer Pricing Adjustment-Performance Guarantee-No risk was involved-Adjustment is not justified-Corporate Guarantee to bank on behalf of Associated enterprise-Directed to recompute arm’s length price of guarantee commission at 0.20 Per Cent.

S. 92B : Transfer pricing-Arm’s length price-Advertisement, marketing and sales promotion expenses. [S. 92CA]

S. 92B : Transfer pricing-Arm’s length price-Advertisement, marketing and sales promotion expenses-Incidental benefit to foreign associated enterprise not to be concluded as brand building exercise. [S.92C]

S. 81C : Undertakings-Special category states-Initial assessment-Commencement Of Business On 28-12-2006-Loss can only be set off against profits of eligible unit in Assessment Year 2008-09. [S. 80IA(5), 80IC(7)]

S. 80IA : Industrial undertakings-Eligible profits-Business of power generation-Handling charges, interest received from employees and miscellaneous Income-Surcharge received from Electricity Boards for delayed payment of receivables in respect of supply of electricity-Interest received from third party for delay in payment-Not Income Generated From Business Operations-Not eligible for deduction-Expansion of unit-Eligible deduction.