S. 115JB : Company-Book profit-Amounts transferred to statutory reserve fund is includible.

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Transactions with Associated Enterprises-Arm’s length price-Question of fact-No substantial question of law.[S.92C, 260A, R.10B(2)(a)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-Failure to furnish evidence-No substantial question of law.[S. 260A, R. 10B, 10C]

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Eligible profits-Captive power plant-Rate at which power supplied to own unit-Market value of supply power to State Electricity Board.

S. 69 : Unexplained investments-Income from undisclosed sources-Huge expenses-Additions to income based on facts-No substantial question of law. [S. 260A]

S. 56 : Income from other sources-Right shares-Allotted to proportionate to shareholding in company-Provision is not applicable in respect of allocation of rights shares allotted below FMV proportionate to his shareholding in company-Gifts-Additional shares received on account of renunciation of rights issue by wife and father-Relatives-Excluded from purview of operation of section 56(2)(vii)(c)-Share premium-Balance sheet-Balance sheet is not drawn up on date of allotment, for arriving at FMV of shares under section 56(2)(vii)(c)(ii), previous balance sheet which is audited and approved in AGM has to be taken into consideration, before allotment of share. [S. 56(2)(vii)(c), R.11UA(1)(c)]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Deletion of addition on facts-No substantial question of law.[S. 37(1), 143(3), 260A]

S. 40(a)(ia): Amounts not deductible-Deduction at source-Amounts paid for services of employees of parent company-No Evidence that amount was reimbursement of actual expenditure as such services by parent company-Disallowance is affirmed.

S. 40(a)(ia): Amounts not deductible-Deduction at source-Recipient filing belated loss return and not paying taxes on income declared-Liable to pay tax deducted at source with interest.[S.201(1)]

S. 37(1) : Business expenditure-Capital or revenue Royalty for use of logo of company-Expenses on employees stock option plan-Revenue expenditure.[Companies Act, 1956,2(15A) 2((37)]