S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Disallowance of expenditure-Existence of international transaction must be established and not inferred-Burden on Revenue to prove existence of international transaction-Amendment introducing deeming fiction in section 92B(2) with effect from 1-4-2015 not applicable to assessment years 2009-2010 and 2012-2013-Orders of assessment set aside. [S. 92B, 92CA, 92D, 92F, 260A]

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Contractor or developer-Road project-No substantial question of law.[S.80IA(4)]

S. 80HHC : Export business-Search and seizure-Block assessment-Genuine export sales-Order of Tribunal allowing the benefit was affirmed. [S. 132, 158BC, 260A.]

S. 80DD : Medical treatment of dependent-Disability-Medical treatment of handicapped dependent-Amendment made by Finance Act, 2022 to section 80DD could not be applied retrospectively to policies taken prior to 2014 as it was not in the interest of disabled persons-Court cannot give retrospective operation to insurance contract which is a commercial contract.[S.80DD(2)(a), Finance Act, 2022, S.21, Art. 32, 142]

S. 69C : Unexplained expenditure-Search-Block assessment-Failure to issue cross examination-Order deleting the addition was affirmed.[S.69A, 132(4), 158BC, 260A]

S. 68 : Cash credits-Share premium-Notices served on companies returning unserved Inspector reporting companies non-existent-Order of Tribunal affirmed-No question of law. [S. 133(6), 260A]

S. 68: Cash credits-Not explained the source-Order of High Court affirming the addition was affirmed-SLP of assessee dismissed on the ground of delay of 388 days and on merits. [Art. 136]

S. 56 : Income from other sources-Amendment with effect from 1-4-2010-Interest on enhanced compensation and compulsory acquisition of agricultural land assessable as income from other sources in assessment year 2016-2017-Order of Tribunal set aside. [S. 56(2)(viii), 145B, 260A, Land Acquisition Act, 1894, S. 28]

S. 45 : Capital gains-Exemption-Entry provider-Survey-Unexplained money-Principle of natural justice-No opportunity of cross examination was given-Order of Tribunal deleting the addition is affirmed. [S. 10(38), 68, 69, 133A, 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Business expenditure-Disallowance-Payments liable to deduction of tax at source-Amount offered to tax by payee and tax thereon paid-AO taking one plausible view-Order not erroneous or prejudicial to Revenue-Principal Commissioner cannot invoke revisional power-Not in default. [S. 40(a)(ia), 201(1), 260A]