S. 92C : Transfer pricing-Arm’s length price-Comparable-Authorities justified in adopting combined accounts approach and confining addition to export segment-Functional similarity-Low turnover-Matter remanded-Draft Assessment order-Assessing Officer bound to follow Dispute Resolution Panel’s Direction. [S. 144C]

S. 92B : Transfer pricing-The term international transaction includes capital financing, which, in turn, also includes guarantee-effects of furnishing corporate guarantee directly percolated to the principal debtor, namely, AE for whom the assessee stood surety-thus, the department contention that the act of furnishing guarantee be treated as shareholder’s activity, is devoid of any merit. [S. 92C, 92CA]

S. 92A : Transfer pricing-Associated enterprises-Arm’s Length Price-Tested party to be determined even when most appropriate method was comparable uncontrolled price-Generation of power for captive consumption-Rate to be taken at rate supplied by Electricity Board to its consumers in open market. [S. 80IA(8), 92CA]

S. 80IB(10) : Housing projects-Survey-On money-Sale of flats-Entitle to deduction. [S. 133(6)]

S. 73 : Losses in speculation business-Share broker-Purchase and sale of shares-Loss incurred from error trades-Not speculative-Allowable as business loss. [S. 28(i)]

S. 72 : Carry forward and set off of business losses-Set off of loss returned by Assessee in subsequent assessment years could not be declined only for the reason that assessment for assessment year in which the losses arose, was in progress and pending. [S. 240]

S. 69A : Unexplained money-Salary income-Cash in hand was deposited in bank-Addition cannot be made as unexplained money. [S. 153A]

S. 69A : Unexplained money-Cash found at office premises-Group companies-Accounted in the books of account-Addition is held to be not valid. [S. 132]

S. 69 : Unexplained investments-On money-Purchase of property from developer-Charge sheet filed by the Central Bureau Of Investigation (CBI) in case of developer-No additional evidence was brought by the revenue-Deletion of addition is held to be justified.

S. 68 : Cash credits-Share application money-All 16 Investor companies replied to notice u/s. 133(6) of the Act-Managing Director was not produced due to ill health-Matter remanded to the Assessing Officer-Order passed by the CIT(A) was cryptic and not speaking order-Order was set aside. [S. 131(1(d), 133(6), 250]