S. 80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Transfer pricing-Captive power plant supplying electricity to non-eligible manufacturing units-Internal transfer pricing must be benchmarked against the landed cost of electricity supplied to consumers by the State Electricity Board-Benchmarked transaction using internal CUP method adopting average annual landed cost of electricity paid by its manufacturing units to State Electricity Boards (SEBs), since CPPs were established for captive use and not for sale to SEBs, internal CUP was the most appropriate method for determining ALP. [S. 80IA(8), 92BA, 92C, 92F(ii); R. 10B(1)(a)]

S. 69B: Amounts of investments not fully disclosed in books of account-Protective assessment-Assessment proceedings in respect of the same were concluded, significance of the protective assessment was lost, and the Petitioner could not make a further claim in respect of the same before the authorities. [S.132, Art. 226]

S. 69B: Amounts of investments not fully disclosed in books of account-Rejection of books and reference to DVO-Addition was affirmed. [S.69A, 142A, 260A]

S. 69: Unexplained investments-Addition-Stock statement furnished to bank-Statement linked to overdraft facility and drawing power-Addition sustained. [S.4, 260A]

S. 69: Unexplained investments-Natural justice-Addition made by the A.O. without furnishing the details of information received from CBEC was set aside-Matter was remanded with a direction to provide such details and grant sufficient time and opportunity of personal hearing to the assessee. [S.69A, 143(3), 144B, Art.226]

S. 68: Cash credits-Share application money-Failing to establish genuineness and creditworthiness-Addition sustained. [S. 260A]

S.54F: Capital gains-Investment in a residential house-No prohibition for using borrowed funds for construction, which would be later settled using sale consideration deposited in the Capital Gains Account Scheme; however, this should be demonstrated with materials to the concerned tax authority.[S. 45, Art. 226]

S. 54EC: Capital gains-Investment in specified bonds-Investment made before sale of property-Exemption restricted to capital gain available on date of investment. [S. 45, 260A]

S. 45 : Capital gains: Computation-Sale consideration-Assessing Officer entitled to substitute actual consideration for consideration stated in sale deed when supported by evidence.[S.48, 260A]

S.43B: Deductions on actual payment-Explanation 5 to S. 43B, which was inserted by Finance Act, 2021 with effect from 1-4-2021 is clarificatory in nature and would apply retrospectively-Due date fell on a date which was a National Holiday, i.e., 15-8-2018, deposit could have been made by assessee only on date which followed National Holiday, i.e., 16-8-2018-the amount deposited on 16-8-2018 was to be allowed as deduction to assessee.[S. 36(i)(va), 139(1), 143(1(a)]