S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Distributor purchasing goods from associated enterprises and reselling without any value addition-Gross profit is a determinative factor-Resale price method is most appropriate.[S. 144C, 260A]

S. 79 : Carry forward and set off losses-Change in share holdings-Companies which public are not substantially interested-Observations of Assessing Officer considering assessment for earlier year of no effect and not sustainable.[S. 260A]

S. 69C: Unexplained expenditure–reassessment–trader in diamonds-Information from Investigation wing-Bogus purchases-Commission agent –Bhanwarlal Jian-Books of account not rejected-Order of Tribunal estimating at six per cent is affirmed. [S. 132(4), 147, 148, 260A]

S. 56 : Income from other sources-Grants received by statutory corporation from Government for construction of housing for Police Department-Interest on deposit of such grant amounts in banks-Assessable as income from other sources-Interest paid not allowable as deduction. [S. 36(1)(iii)]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Capital or revenue-Pre-payment of deferred sales tax liability-Capital receipt.[S. 4, 260A]

S. 40A(3): Expenses or payments not deductible-Cash payments exceeding prescribed limits-Amendment with effect from 1-4-2009-Disallowance of payments exceeding specified limit to a single person on a single day-No evidence of separate payments made on a single day to assessee-Disallowance justified. [R.6DD]

S. 32: Depreciation-Intangible assets-Business and commercial brand equity are goodwill-Depreciation allowable. [S. 260A]

S. 28(i): Business income-Capital or revenue-Subsidy-Exemption from sales tax granted by State Government-Assessable as revenue receipt.[S. 4, The U.P. Trade tax Act, 1948, S. 4A, 8A(2) 29A]]

S.14A : Disallowance of expenditure-Exempt income-Restriction of disallowance to the extent of two per cent. of dividend income Proper-Reserves and surplus amount exceeding investment-Presumption that investments out of own interest-bearing funds Disallowance not attracted.[S. 36(1)(iii) R.8D, 260A]

S.14A : Disallowance of expenditure-Exempt income-No borrowed funds utilised for investment-Order of Tribunal deleting the disallowance affirmed.[R.8D(2)(iii)]