S. 119 : Central Board of Direct Taxes-Circular-Condonation of delay of 1257 days-Accumulation of income-Form no 10-Delay was condoned-Directed to file application under section 154 of the Act. [S. 11(2), 119(2)(b), R. 17, Form No.10B, Art. 226]

S. 115JB : Company-Book profit-Provision for doubtful loans and advances Loss-Actual and certain-No upward adjustment required. [S.115JB(2)(c)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Transfer Pricing Officer, including high brand value companies-Functional similarity alone not decisive factor-Exclusion of such comparables in subsequent assessment year-Direction to exclude the two comparables.[S.92CA]

S. 69C : Unexplained expenditure-Cash purchases and receipts for job work on the basis of seized document Estimation of gross profit at 8 per cent.-Question of fact-Order of Tribunal affirmed.[S. 132, 260A]

S. 69C : Unexplained expenditure-Difference in stock-Reconciliation was filed-Order of Tribunal affirmed-No substantial question of law. [S. 260A]

S. 68 : Cash credits-Shares-Failure to prove genuineness of transaction-Order of Tribunal affirmed.[S. 132, 133A, 153C, 260A]

S. 68 : Cash credits-Principle of natural justice-Assessee must be given adequate opportunity to be heard and also to cross-examine witnesses whose statements have been relied on to make additions. [S. 260A]

S. 57 : Income from other sources-Deductions-Expenditure for purposes of earning-Borrowing money and lending it to others-Interest on borrowed money-Allowable as deduction.[S.56, 57(iii)]

S. 56: Income from other sources-Shares at premium-Valuation of shares Discounted cash flow method Determination of fair market value of shares under rule 11UA-Order of Tribunal affirmed.[S. 56(2)(viib), R. 11UA]

S. 40A(3) :Expenses or payments not deductible-Ad-hoc disallowance-Cash payments exceeding prescribed limits-Deletion of disallowance by Commissioner (Appeals) on examination of vouchers confirmed by Tribunal is affirmed [S.145 260A]