S. 143(3): Assessment – Search and Seizure — Unaccounted income — Medical college — Donations and capitation fees — Onus upon revenue – Addition based on statement by Chairman of Trust — No Cross-Examination Allowed- Addition is deleted [S. 69 , 132, 147 , 148 ]
S.143(3): Assessment – Unverifiable purchases — Bogus purchases- Sales accepted- Failure by some parties to respond to notice- Entire purchases cannot be disallowed – Directed to estimation of gross profit rate on the turnover . [ S.37(1), 69C ]
S.143(3) : Assessment -Revision — Addition made pursuant to revisional order — Tribunal quashing revisional order — Resultant Proceedings would not survive [ S.14A, 115JB , 254(1), 263 ]
S. 132(4) : Search and seizure – Statement on oath – Short term capital gains- Offered in statement recorded during search – Brought forward capital loss of earlier years – Eligible to be set off against short term gains of current year – Set off of loss not to be denied on ground that not claimed in statement recorded during search [ S. 74 ]
S.92C: Transfer pricing -Arm’s length price — Exchange rate fluctuations —Taken part of operating margin [ S.92CA ]
S.92C: Transfer pricing — Arm’s Length Price — Delay in realisation of trade debts — Uniform policy -Associated enterprises and non- enterprises — Addition of notional interest is held to be not justified . [ S.92B ]
S.92C: Transfer pricing — Arm’s length price — Manning service fee —Addition is deleted .
S. 92C : Transfer pricing – Arm’s length price – Huge related party transactions — Unreliable financials — Not Comparables [
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 ]