S. 145 : Method of accounting-Valuation of stock-Bank-Premium paid at time of purchase of securities-Valuation of securities held to maturity category at cost-Followed consistently-Addition is held to be not justified-Loss on shifting of securities from held for trading and available for sale categories to held to maturity category-allowable as business loss. [S. 28(i)]

S. 143(3) : Assessment-Business income-Joint Development Agreement-Percentage of completion method-Entries in books of account-No addition could be made based on difference between Form 26AS and amount shown in profit and loss account. [S. 28(i), 194A]

S. 143(3) : Assessment-Income from undisclosed sources-Short-term capital loss-Bogus transaction-Denial of opportunity of cross examination-Disallowance not solely on basis of statement of persons but on other corroborative materials-Denial of opportunity to cross-examine and mentioning wrong section would not render the assessment order null and void. [S. 68, 69C]

S. 143(3) : Assessment-Same turnover cannot be taxed in hands of two different assesses-Addition unsustainable-AO is directed to adopt Profit ratio of eight Per Cent as net profit on gross receipts [S. 147, 148]

S. 133A : Power of survey-Undisclosed Sales-Quantity tally of stock maintained-Merely on the basis of confessional statement addition cannot be made.

S. 92C : Transfer pricing-Arm’s length price-Comparables-High degree of brand value-Cannot be comparable.

S. 92C : Transfer pricing-Arm’s length price-Advertising and promotion expenses-Reimbursement of expenses-Adjustment is held to be not valid-Additional evidence-Packaging, design cost-Issue remanded-Depreciation-Good will-Actual cost-Matter remanded. [S. 32, 92CA(3), 234A, 234B, 254(1)]

S. 68 : Cash credits-Cash deposited of sales-Sales cannot be assesse as cash credits-Only gross profit can be estimated-Ad hoc disallowance of 1/5 of expenses is held to be not justified. [S. 37(1), 143(3)]

S. 68 : Cash credits-Identity, genuineness and creditworthiness established-Deletion of addition is held to be justified-Unintended mistakes-Remand report-Deletion of addition is held to be justified. [S. 69C]

S. 56 : Income from other sources-Capital asset-Agricultural land-If agricultural land does not fall in definition of capital asset, difference between district level committee value and sales consideration cannot be brought to tax-Matter remanded. [S. 2(14)(iii), 56(2)(vii)(b)]