S. 92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-Captive power plant-Transfer pricing-State Electricity Board tariff not comparable-Arm’s Length Price to be determined on internal comparable-Eligible business-Non-claim of deduction under section 80-IA-Does not exclude applicability of section 92BA.[S.80IA(8), 80IA(10), 80IB 92CA, R. 10B]

S. 90 : Double taxation relief-Non-resident-Delaware Limited Liability Company-Fiscally transparent entity-Liable to tax in USA-Treaty benefits available-DTAA-India-USA.

S. 69C: Unexplained expenditure-Bogus purchases-Books of account accepted by Commissioner (Appeals)-Purchases at prevailing market rates-No profit embedded-Addition deleted.[S.133(6) 145(3)]

S. 69C : Unexplained expenditure-Cash payments reflected in seized documents duly reconciled with books of account-Addition rightly deleted-Recovery from farmers towards unloading charges-Common trade practice-No evidence of receipt by assessee-Addition deleted-Cash receipts and sale of de-oiled cakes-Entries reflected in books-No rebuttal by Assessing Officer-Addition deleted-Additional income voluntarily surrendered-Telescoping against additions-Separate addition not justified-Excess stock-Difference only in valuation and not quantity-Books not rejected-Addition deleted. [S.68, 132, 145(3)]

S. 45 : Capital gains-Capital loss-Demerger-Transfer of assets and liabilities to Special Purpose Vehicles-Conditions of demerger not fulfilled-Long-term capital loss allowable.[S.2(19AA, 47]

S. 44 : Insurance business-Expenditure relating to exempt income-Section 14A not applicable to insurance companies.-Reserve for unexpired premium-Double taxation to be avoided-Matter restored for verification.[S.14A, R.8D, R.6E]

S. 40(a)(ii) : Amounts not deductible-Rates or tax-Business expenditure-Education cess and higher education cess-Part of tax-Deduction not allowable.

S. 40(a)(i); Amounts not deductible-Deduction at source-Non-resident-Business expenditure-Reinsurance premium paid to non-resident reinsurers-Not chargeable to tax in India-No liability to deduct tax at source. [S. 195]

S. 37(1) : Business expenditure-Personal expenses of directors-No evidence that expenditure belonged to assessee-Addition deleted.

S. 37(1) : Business expenditure-Advertisement and sales promotion expenses-Real estate project undertaken on ownership basis-Revenue expenditure allowable.