S. 92C : Transfer pricing-Arm’s length price-Interest rate-Accepted earlier year as well as subsequent assessment years-Revenue could not be allowed to make a departure in case of rate of interest for relevant assessment year.
S. 92C : Transfer pricing-Arm’s length price-Interest rate-Accepted earlier year as well as subsequent assessment years-Revenue could not be allowed to make a departure in case of rate of interest for relevant assessment year.
S. 68 : Cash credits-Foreign gifts-Gift was not genuine-Deletion was held to be not justified-Service of notice was held to be valid. [S. 148, 149]
S. 44AB : Audit of accounts-Business-Profession-Guidelines issued by the Institute of Chartered Accountants of India-Conflicting judgements of different High Courts-Transfer petition filed before Supreme Court. [Chartered Accountants Act, 1949, S. 22]
S. 37(1) : Business expenditure-Research and development-Allowable as revenue expenditure.
S. 37(1) : Business expenditure-Claim not made in original return-Prior period expenses-Allowable as deduction-Issue not to be remitted back to the Assessing Officer. [S. 43B, 254(1), R. 46A(3)]
S. 36(1)(vii) : Bad debt-Writing off of irrecoverable loan in books of account sufficient to claim deduction for bad debts-Money lending licence is not required to be in money lending business to claim said deduction-Matter remanded to Appellate Tribunal. [S. 37(1)]
S. 14A : Disallowance of expenditure-Exempt income-Non-recording of satisfaction-Disallowance is held to be unjustified. [R. 8D]
S. 12A : Registration-Trust or institution-Delay in filing Form No 10B-Denial of exemption is held to be not justified. [S. 119, Art. 226]
S. 12A : Registration-Trust or institution-Development and maintenance of ports-General public utility-Entitle to registration. [S. 2(15)]
S. 10A : Free trade zone-Set off of losses-Other income-Order of Tribunal is affirmed.