S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Sale of low volume of exports cannot be considered as valid comparable-Adjustment made adopting the ALP of interest at six moths average of LIBOR plus 3. 5 % % is not sustainable.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-TPO accepted cost allocation on basis of average total assets and third party sales, but refused to accept allocation done on basis of head count-Addition on account of management fee is deleted. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Property is purchased by an Indian enterprise from its AE and is resold as such without any value addition, it is RPM, being specific method, which would hold field in preference to TNMM-Percentage of related party transactions of expenses of selected company was more than 57 per cent of total expenses incurred by it, selected company could not be held as comparable-Comparable-Assembly activity-Engaged in multi-dimensional ranging business and also into field of constructing-production of electronic weighing scales, currency counting machine-business of manufacturing, marketing and servicing of road and rail weigh bridges-Not comparable. [S. 92CA]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Certificate in the month of April/May 1995-started telecommunication services after 1-4-1995 and would be eligible for deduction-Interest and miscellaneous income-Allowable deduction. [S. 80IA(4)(ii), 80IA(2A)]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Agreement with State Government /Statutory bodies-Developing new infrastructure facilities. i. e. irrigation projects-Entitle to deduction-Interest on mandatory fixed deposit as security against bank guarantee-Eligible for deduction. [S. 80IA(4)(i)]

S. 80G : Donation-Religious purpose-Registered under section 12AA-Directed to grant approval under section 80G(5) of the Act. [S. 12AA, 8OG(5) (vi))]

S. 69A : Unexplained money-Undisclosed professional receipts-40% of expenses are allowed on estimate basis-Interest income from bank addition is justified. [S. 28(i), 37(1)]

S. 69 : Unexplained investments-Income from undisclosed sources-Assessment-Bogus purchases-Order of CIT(A) restricting disallowance of purchases to 5 per cent of alleged bogus purchases is affirmed. [S. 143(3)]

S. 68 : Cash credits-Sale of ancestral gold and savings-Addition is deleted-Reassessment notice is not justified. [S. 147, 148]

S. 68 : Cash credits-Search and survey-Demonetization-Cash deposits-Negligible stock-in-trade-Annonymous buyers-Addition is affirmed. [S. 131, 292C, Indian Evidence Act, 1872, S. 26, 31, 34, 92]