S. 92C : Transfer pricing-Arm’s Length Price-CBDT Instruction No. 3 of 2003 Mandatory-Precedent. [S. 92CA]
S. 92C : Transfer pricing-Arm’s Length Price-CBDT Instruction No. 3 of 2003 Mandatory-Precedent. [S. 92CA]
S. 92C : Transfer pricing-Arm’s length price-Net margin method-Finding of fact-No question of law. [S. 94B, 260A]
S. 57 : Income from other sources-Deductions-Fixed deposits- Interest payment for earning income is held to be deductible. [S. 56, 57(iii)]
S. 54F : Capital gains-Investment in a residential house-Purchase or construction need not be made out of sale consideration for capital asset. [S. 45]
S. 45 : Capital gains-Unabsorbed depreciation-Set off against long-term capital gains is permissible-Block of assets-Sale of land and building-Land and building valued separately-Held to be proper. [S. 2(11), 32(2), 71, 72, 73]
S. 43(5) : Speculative transaction-Hedge against loss-Exporter of cotton entering into forward contracts-Loss Incurred-Not a loss in speculative transaction -Entitled to deduction of loss. [S. 28(i)]
S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Banking facilities available-No evidence of compelling circumstances justifying payments-Disallowance is justified. [R. 6DD]
S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-No reasonable cause to make payment- Disallowance is held to be justified. [R. 6DD]
S. 37(1) : Business expenditure-Service charges paid to employees in terms of agreement entered into under Industrial Disputes Act-Allowable as deduction. [Industrial Disputes Act, 1947, S.18(1)]
S. 37(1) : Business expenditure-Capital or revenue-Loan to purchase plant and machinery-Increase in liability due to fluctuation in foreign exchange rates-Capital expenditure.