S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Transfer pricing study report must be reliable and correct-Functional asset and risk analysis required to be done-Rejection of transfer pricing study report is proper-Benchmarking of transactions-Selection of comparable companies-Working capital adjustment allowed in subsequent years-Matter remanded for verification [S. 92CA]

S. 90 :Double taxation relief-Capital gains-Sale pf shares-Tax Residency certificate issued by Mauritius tax authority is unquestionable-Not shell or conduit company-Beneficial owner of capital gains-Capital gains is exempt from taxation-The Assessing Officer is directed to factually verify the aspect, if the shares were acquired after April 1, 2017 and sold prior to March 31, 2019, the benefit under article 13(3B) could be given to that extent. [Art, 13(3A) 27A]

S. 80P : Co-operative societies-Interest earned on deposits with Co-Operative Banks-Eligible for deduction. [S.2(19), 80P(2(d), Banking Companies Act, 1949, 5(1), Co-operative society registered under the Co-operative Societies Act, 1912, Maharashtra Co-Operative Societies Act, 1960, S.2(10)]

S. 80P : Co-operative societies Credit facilities to its members-Nominal members-Issue restored to Assessing Officer to examine claim following the decision of Supreme Court in Mavilayi Service Co-Operative Bank L td. v. CIT (2021) 431 ITR 1 (SC)-Interest earned from deposits kept with bank-Income from other sources-Corresponding expenditure incurred in earning interest income should be allowed as deduction-Issue restored to Assessing Officer-Cash credits-Demonetisation-Money deposited by its members towards repayment of loans and pigmy deposits-Stopped collection after receipt of Notification Dated 14-11-2016 issued by Reserve Bank Of India-Cash deposits can not be treated as unexplained money-Addition is deleted [S. 56,68, 80P(2)(a)(i), 80P(2)(d)]

S. 80P : Co-operative societies-Deposits made out of surplus funds with Co-Operative Banks and scheduled Banks-Entitled to deduction of interest.[S.80P(2)(a)(i), 80P(2(d), Maharashtra Co-operative Societies Act, 1960,]

S. 80IC : Special category States-Delay in filing return-Mistake of Auditor-Delay condoned-Fall in gross profit-Books of account not rejected-Addition is deleted. [S.80AC, 139, 145]

S. 80IC : Special category States-Eligible profits-Disallowance of sales promotion expenses-Freebies-Enhancement of profits of eligible business-Directed to recompute eligible profits and allow deduction-Profit derived from sale of scrap-Eligible for deduction-Central Board Of Direct Taxes Circular No. 37 Of 2016, Dated 2-11-2016.]

S. 80G : Donation-Time-limit for application for approval-Dismissed on ground that application was made beyond time-Limit Board circular extending time-Matter remanded to the CIT(E) to decide in accordance with law.[S.80G(5), Form No 10B]

S. 80G : Donation-Application for registration dismissed on ground Form 10AB was filed beyond time prescribed-Central Board Of Direct Taxes Circular No. 7 Of 2024, Dated April 25, 2024 (2024) 463 ITR 14 (St)-Directed Commissioner (E) to consider Assessee’s application and grant exemption-Delay of 243 days in filing of appeal is condoned.[S.12A,80G(5)(iii), 253(5), Form No 10A, 10AB]

S. 70 : Set off of loss-One source against income from another source-Same head of income-Loss incurred on sale of shares on Stock exchange platform-Securities transaction tax paid-Eligible to be set off against long-term capital gains earned from sale of unlisted shares. [S. 10(38), 45, 71 74]