S. 115JB : Book profit – Capital gains —Indexed cost of acquisition to be considered [ S.45 , 48 ]

S. 92C : Transfer pricing – Arm’s length price –Comparable uncontrolled price method or the transactional net margin method- Question of fact- Commission – Finding of fact . [ S.37(1) , 254(1) 260A ]

S. 92C : Transfer pricing – Arm’s length price – Instruction of CBDT is binding on revenue -Instruction No .3 of 2003 ( 2003 ) ( 261 ITR 51 (St) [ S.92CA ]

S. 92C : Transfer pricing – Arm’s length price – Internal transactional net margin method -Method adopted – No question of law [ S. 92 to 94B, 260A ]

S. 80IA :Industrial undertakings – Infrastructure development- Appellate Tribunal – Container freight station — Part of inland port — Tribunal cannot ignore decision of co-ordinate Bench- Matter remanded to the Assessing Officer to apply the decision of Tribunal [ S. 253 , 254(1)

S.57: Income from other sources — Deductions —Interest payment for earning of income – Held to be deductible . [ S.56 ]

S.54F : Capital gains- Investment in a residential house Sale of capital asset and construction or purchase of residential house within stipulated time —Purchase or construction need not be made out of sale consideration for capital asset . [ S.45, 54(1) ]

S. 50B : Capital gains – Slump sale – Assets transferred to Subsidiary- Allotment of Shares — Scheme approved by High Court — Not slump sale for purposes of capital gains Tax — The transfer, pursuant to approval of a scheme of arrangement, was not a contractual transfer, but a statutorily approved transfer and could not be brought within the definition of the word sale -Claim which was not raised in return or revised return – Appellate authorities must consider the claim if facts are on record – No estoppel in taxation law – [ S.2(42C) 45 , 54EC , Companies Act , S. 393, 394, Transfer of property Act, 1882 S.118 , Sale of Goods Act , 1930 , S.2(10) ]

S.45 : Capital gains —Block of assets – Land and building —Valued separately — Held to be justified [ S. 2(11) ]

S. 43D : Public financial institutions – Co-Operative Bank -Real income — Interest on non-performing assets cannot be taxed on accrual basis- Amendment should apply to pending matters [ S.80P(4) 145 ]