S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Functionally different-Comparable to be excluded-Paying Technical support service fees to Associated Enterprise-Matter remanded–External commercial borrowings-Adopting Arm’s Length interest rate as per Master Circular of Reserve Bank of India-Transfer Pricing Officer adopting rate based on Libor-Adjustment upheld-Interest cost-Interest On Overdue Receivables from Associated Enterprises-Receivables constitute international transactions-Transactional Net Margin Method-Net Margin computed would consider interest cost-Addition is deleted-Expenses reimbursed-Addition upheld in absence of evidence. [S.92CD]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Business process outsourcing services and doing actual work based on specifications provided by Associated Enterprises-Company functionally different and not comparable to be excluded–Extraordinary event of acquisitions renders is not comparable. [S.92C(3)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Reimbursement of expenses on actual-cost basis-Meeting of statutory duties, fees and other charges-Adjustment is not valid. [S.92CA]

S. 68 : Cash credits-Unexplained sundry creditors-Summons issued to creditors returned-Unsigned copies of ledger accounts-Confirmations signed only by assessee and not by creditors-Matter remanded. [S. 131(1)(d)]

S. 68 : Cash credits-Unaccounted money-Substantial addition is made-Deletion of addition is justified.

S.54F : Capital gains-Investment in a residential house-Monthly tenancy-Owner entering into development agreement –Development of building-Two flats in new building is allotted to assessee and spouse-Market value as consideration-Relinquishment of tenancy rights in lieu of allotment of new flat-Entitle to exemption –Power of Tribunal-Death of the assessee during pendency of appeal-Tribunal has the power to decide the appeal on the relevant material [S. 45, 254(1), ITAT R.1963, R.26]

S. 43(1) : Actual cost-Depreciation-Amalgamation of Banks Amalgamating Bank Ceases To Exist-Tribunal Right In Allowing Depreciation On Assets Taken Over Pursuant To Amalgamation With Assessee [S. 32, 43(1), Explanation 7]

S. 37(1): Business expenditure-Capital or revenue-Lease premium paid at commencement of lease-Allowable proportionately as revenue expenditure over the lease period-Addition is deleted.

S. 35D : Amortisation of preliminary expenses-Only small amount as capital expenditure-Balance representing one-Fifth Of preliminary expenses is allowed. [S. 37(1)]

S. 32 : Depreciation-Rate of depreciation-Plant and machinery-Vacuum Cleaner, Water Dispenser and Epabx Machine-Not furniture and fittings-Eligible to depreciation at rate of 15 Per Cent. [S. 32 (1)(ii)(a), 32A]