S. 92C : Transfer pricing-Arm’s length price-Comparable-Company whose audited financial data for previous year available in public domain not to be discarded merely because it has different financial year-Expenses on travel, boarding and lodging, etc. of its employees during outstation visits-Assessee should have marked up expenses by a profit-margin before making recoveries-Weighted average period of realization with respect to all invoices was only 20.52 days-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Net margin method-Adjustments to be restricted to international transactions and not to be applied to entire segment of manufacturing activity-Entitled to benefit of tolerance range of +5 Per Cent. [S. 92CA]

S. 92B : Transfer pricing-Associated enterprise-Performance guarantee-International Transactions-Transfer Pricing Adjustment-Performance Guarantee-No risk was involved-Adjustment is not justified-Corporate Guarantee to bank on behalf of Associated enterprise-Directed to recompute arm’s length price of guarantee commission at 0.20 Per Cent.

S. 92B : Transfer pricing-Arm’s length price-Advertisement, marketing and sales promotion expenses. [S. 92CA]

S. 92B : Transfer pricing-Arm’s length price-Advertisement, marketing and sales promotion expenses-Incidental benefit to foreign associated enterprise not to be concluded as brand building exercise. [S.92C]

S. 81C : Undertakings-Special category states-Initial assessment-Commencement Of Business On 28-12-2006-Loss can only be set off against profits of eligible unit in Assessment Year 2008-09. [S. 80IA(5), 80IC(7)]

S. 80IA : Industrial undertakings-Eligible profits-Business of power generation-Handling charges, interest received from employees and miscellaneous Income-Surcharge received from Electricity Boards for delayed payment of receivables in respect of supply of electricity-Interest received from third party for delay in payment-Not Income Generated From Business Operations-Not eligible for deduction-Expansion of unit-Eligible deduction.

S. 68 : Cash credits-Gold smith-Depositing cash in the Bank-Cash withdrawal-Marriage gifts-one third of deposit was accepted as withdrawal-Remanded for verification.

S. 68 : Cash credits-Shares allotted-Investment by managing director-Discharged the burden-Addition held to be not valid.

S. 68 : Cash credits-Investment in earlier years-Selling during the year-Addition cannot be made. [S. 132]