S. 92C : Transfer pricing-Arm’s length price-Amount paid as trade mark fees to associated company in Singapore-Trade Mark was being used for several years past-Disallowance of trade mark fees is held to be justified-Corporate and Bank guarantees-Financial services- Direction to modify the claim is justified-Clarificatory Amendment can have retrospective operation. [S. 47(iv), 92B]

S. 80IA : Industrial undertakings- Infrastructure development-Development and leasing of premises in software park-Assessable as business income- Entitle to deduction. [S. 28(i), 80IA(4)]

S. 80HHC : Export business-Shipping agency fees, hire charges of machinery and installation must be reduced on net Basis-Proceeds of services and repairs by Shipyards not to be reduced. [S.80HHC Explanation (baa)]

S. 68 : Cash credits- Burden to establish identity of creditors, genuineness of loan transaction and capacity of lender-Addition is held to be justified. [S. 260A]

S. 68 : Cash credits- Block assessment- Matter remanded to the CIT (A) to consider unexplained cash credits . [S. 132, 143(3), 147, 158BA, 254(1)]

S. 64 : Clubbing of income-Minor child-Interest from firm-Accounting year ended on December 31, 1975-Income cannot be clubbed for the relevant year. [S. 64(1)(iii), 66, 256(1)]

S. 56 : Income from other sources-Individual-Natural living individuals-Donation received by discretionary Trust-Assessable as income from other sources. [S. 2(24)(xv), 2(31)(v), 56(2)(vii)]

S. 45 : Capital gains-Transfer of shares to subsidiary in Mauritius- Transfer of Shares from subsidiary to Private Equity Fund incorporated in Cayman Islands-Transactions are not genuine-High Court has the power to find out if transactions are genuine.

S. 45 : Capital gains-Agricultural land- Barren land-Sold to developer with in short period after purchase-Land not agricultural- Gains not exempt from tax. [S. 2(14)(iii), 10(1) Bombay Tenancy and Agricultural Lands Act, 1948, S. 63]

S. 44AD : Presumptive taxation-Individual partner of firm engaged in eligible business- Remuneration and interest could not be treated as gross receipts- Not entitled to benefit. [S. 28(v), 44AD(2)]