S. 92C : Transfer pricing-Arm’s length price-Management fee-Documents filed to justify and availment of services have to accept value of management services as claimed by assessee-Functional similarity-Assessee involved in advertising agency, data not available in public domain for comparability of business support system segment of said company, it could not be compared to marketing support service provider-Income from exhibitions and events, should be excluded from comparable list to marketing support service provider.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Software consultancy-Functional similarity-Company engaged in providing both software products as well as software development services could not be accepted as comparable-A company engaged in providing information services could not be accepted as comparable-A company providing information services could not be accepted as comparable.

S. 69A : Unexplained moneys-Loan-Confirmation from such two persons from whom money was received as ‘temporary loan’ was not produced-Matter remanded back to decide afresh. [S. 254(1)]

S. 69 : Unexplained investments-Immoveable property-Valuation report-Difference was less than 15 %-Addition is held to be not valid. [S. 132, 153C]

S. 69 : Income from undisclosed sources-Survey-Addition based on statement given to survey team on documents found indicating receipt of large amounts-No retraction-Addition upheld. [S. 133A]

S. 68 : Cash credits-Share capital-Submitted share application form, copy of share certificates, copy of board resolution, certificate of incorporation etc. with respect to all investor and all investor entities had sufficient net worth to make investment, additions as unexplained cash credit was unjustified. [S. 147, 148]

S. 68 : Cash credits-various evidences filed including financial statement of creditor to prove his identity and creditworthiness and genuineness of transactions, merely for reason that loan were received in cash was unjustified.

S. 68 : Cash credits-Addition is not sustainable where the assessee-company has been able to prove the identity of the investor, its creditworthiness and genuineness of the transaction. [S. 69C, 147, 148]

S. 68 : Cash credits-Unexplained investments-Seizure of Banakhat duly signed by the assessee-Addition U/s 68 on account of non-availability of ROI and Bank account of lender-Held that AO has not brought any material or evidence to disprove the genuineness of information submitted by the assessee-The appeal of the revenue is dismissed. [S. 69, 153A]

S. 54F : Capital gains-Exemptions-investment in house property in name of assessee’s widowed daughter was allowable-Direct nexus between sale consideration received and investment in house property-Entitle to exemption. [S. 45]