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.
S. 68 : Cash credits-Gold smith-Depositing cash in the Bank-Cash withdrawal-Marriage gifts-one third of deposit was accepted as withdrawal-Remanded for verification.
S. 68 : Cash credits-Shares allotted-Investment by managing director-Discharged the burden-Addition held to be not valid.
S. 68 : Cash credits-Investment in earlier years-Selling during the year-Addition cannot be made. [S. 132]
S. 68 : Cash credits-Unsecured loan-Confirmation and bank statement was filed-Interest was paid after deduction of tax at source-Addition was held to be not valid. [S. 12AA]
S. 45 : Capital gains-Full value of consideration-Addition cannot be made on the basis of receipts shown in form No 26AS-Transfer-Matter remanded to verify whether there was transfer of land in Terms of Section 53 A of transfer of property. [S. 2(27)(v), Transfer of property Act, 1882, S. 53A]