S. 92C : Transfer pricing – Arm’s length price -A debt-free company — No interest paid to creditor or supplier nor interest earned from unrelated party- Adjustment of interest is held to be not warranted .
S. 92C : Transfer pricing – Arm’s length price -A debt-free company — No interest paid to creditor or supplier nor interest earned from unrelated party- Adjustment of interest is held to be not warranted .
S. 92C : Transfer pricing – Arm’s length price – Information enabled technology services -Comparable-Extraordinary events taking place in relevant period — Excluded from comparable – Interest receivables – No separate adjustment is required – Denial of exemption is not justified [ S. 10A , 92CA ]
S. 80IA :Industrial undertakings – Infrastructure development-
Generation Of Electricity — Initial assessment year — Not required to notionally reduce losses arising from eligible business in earlier years already set off against other business – Losses arising in eligible business subsequent to earmarking of initial Assessment year to be governed by embargo placed in section 80IA(5) of the Act [ S.70 , 71 ,72 ,80IA(4),80IA(5) ]
S. 69C : Unexplained expenditure – Bogus purchases –
Accommodation entries —Trading in gold jewellery – Enhancement by CIT (A) directing to add entire purchases was deleted – Estimate of 10% of bogus purchases Assessing Officer is affirmed . [ S. 132 ]
S. 69 :Unexplained investments – Silver and jewellery belongs to family members – Declared in the wealth tax return to be considered – Addition is held to be not valid [ S.69A , 132 ]
S.68: Cash credits — Balances from earlier years – Matter remanded to the Assessing Officer .
S. 68 : Cash credits – Investment in company – Not producing criminal complaint to prove the source – Addition is held to be justified .
S. 68 : Cash credits – Journal entry – Share application money — Cheques neither presented nor encashed in accounting year- Addition cannot be made .
S.68: Cash Credits — Unsecured Loans —Banking channels- Subsequently adjusted against booking of flat – Addition is held to be not valid .
S.68: Cash credits — Circuitous cash deposits – Three bank accounts – Salaried employee- Addition was confirmed to the extent of Rs 7 ,38 ,000 ]