S. 92B : Transfer Pricing-Arm’s Length price-In absence of any evidence of existence of international transactions between assessee & its foreign associated enterprise arising out of advertisement & marketing promotion determination of Arm’s length price does not arise requiring no transfer pricing adjustment.
S. 92B : Transfer pricing-International transaction-Corporate guarantee is not international transaction prior to amendment of section 92B w.e.f. 1-4-2012.
S. 80P : Co-operative societies-Credit facilities to members-Deposit from members-Penalty proceedings wrongly mentioning as Co-Operative bank-Deduction cannot be denied. [S. 80P(2)(a)(i), 271D]
S. 80IE : Undertakings-North-Eastern states-Ineligible units-Disallowance cannot be made by applying provisions of section 80IA(10) of the Act. [S. 80IA(10)]
S. 80IC : Special category States-Initial assessment year-Substantial expansion within a period of 10 years-Substantial expansion was undertaken would become initial assessment year-Entitled to 100 per cent deduction for a total period of ten years as provided in section 80IC(6) of the Act. [S. 80IC(6)]
S. 80IAB : Undertaking-Development of Special Economic Zone-Lease rental-business’ of developing-Eligible for deduction.
S. 80IA : Industrial undertakings-Infrastructure development-solid waste management-Agreement with Municipal corporation-Substantial work by assessee-Entitle deduction.
S. 80IA : Industrial undertakings-Deduction disallowed for interest on delayed payments-bore no nexus to the industrial activity of power generation-disallowed.
S. 69 : Unexplained investments-NRI purchasing property in India-Gave satisfactory explanation of source of fund-Even if explanation was not satisfactory no addition can be made.
S. 69 : Unexplained investments-Cash deposited in bank account-Remand report-Once the AO has examined the document so produced by the assessee and recorded his satisfaction regarding the identity of the donors, genuineness of the gifts and sources of such gifts, the assessee has discharged the necessary onus cast on her and the addition directed to be deleted.