S. 92C : Transfer pricing-Arms’ length price-Avoidance of tax -International transaction-TNMM- While determining ALP of international transactions, benchmarking should be done only on associated enterprise or related party transactions and not with respect to entire turnover.[S. 260A]

S. 92C : Transfer pricing-Arms’ length price-Avoidance of tax -International transaction- Business of distribution of solar products- There was no value addition done by assessee on products purchased and subsequently sold by it. On facts, assumption of TPO was erroneous and RPM was most appropriate method-Order of Tribunal affirmed. [S.92CA, 260A]

S. 92C : Transfer pricing-Arms’ length price– Avoidance of tax -International transaction-Gross delay of 434 days in filing SLP had not been satisfactorily explained by revenue- SLP of revenue dismissed.[Art. 136]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax -International transaction-SLP of revenue dismissed on account of failure to explain 597 days of delay. [Art. 136]

S. 80-IC : Special category states-Substantial expansion-Initial assessment year-Since there was an inordinate delay of 412 days in filing review petition which had not been satisfactorily explained, review petition was dismissed on ground of delay as well as on merits. [Art. 136]

S. 80-IC : Special category states-Entitle to 100% deduction- Order of High Court allowing only 25 % deduction is set aside.[Art. 136]

S. 69C : Unexplained expenditure-Bogus purchases-No discrepancy between purchases and sales shown -Entire purchase cannot be added-Order of High Court dismissed the appeal of the revenue is affirmed.[S. 260A]

S. 69C : Unexplained expenditure-Bogus purchases-No disccrpency between purchases and sales shown -Entire purchase cannot be added-Order of High Court dismissed the apepeal of the revenue is affirmed-SLP delay of 606 days-SLP of revenue dismissed on account of delay as well as on merits. [S. 268A, Art. 136]

S. 69B : Amounts of investments not fully disclosed in books of account -Survey-Shortage of closing stock of finished goods and raw material-Sales outside books of account- The contention of the assessee that only GP should be added was rejected-On writ High Court affirmed the order of the Commissioner. [S. 264, Art. 226]

S. 68 : Cash credits-Sale of shares-Information received from investigation wing- Sold through recognised stock exchange-Paid Security transaction- Delay of 292 days-SLP dismissed-Delay was not satisfactorily explained. [S. 10(38), 45, Art. 136]