S. 127 : Power to transfer cases-Co-ordinated investigation-Subjective satisfaction of authorities-Power is administrative in nature and not circumscribed by express language-Transfer justified where search reveals incriminating material across group concerns-No mala fides-Writ appeals dismissed. [Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Return-Condonation of delay-Delay in filing Form No. 10-ID-Reasonable cause-Benefit claimed in return cannot be denied for procedural lapse-Authorities directed to accept belated Form as valid. [S. 119(2)(b), 139, Form 10-IC, Art. 226]

S. 119 : Central Board of Direct Taxes-Instructions-Circular- Revised return-Intimation-Condonation of delay-Refund-Mistake in filling appropriate columns in the return-intimation by CPC-CBDT ought to have condoned the delay in fling the corrected/ revised return-Writ petition allowed. [S. 119(2(b), 139(5), 143(1)(a), 237, Art. 226]

S. 92C : Transfer Pricing-Arm’s length price-Sale of power by eligible unit claiming deduction u/s 80-IA to non-eligible units-Market for electricity regulated-CUP Method-Rates charged by SEB constitute appropriate external CUP. [S. 80-IA(8), 92BA, 260A]

S. 64 : Clubbing of income-Minor child-Income includes loss-Loss of minor can be clubbed in mother’s hands and not necessarily only in father’s hands-Order of Tribunal set aside. [S.64(IA), 260A]

S. 56 : Income from other sources-Capital gains-Agricultural land-Interest on enhanced compensation for acquisition of land-Interest on delayed payment under the Land Acquisition Act partakes the character of compensation-Eligible for exemption u/s 10(37) where land is agricultural-Not “interest” u/s 2(28A), hence S. 56 not attracted. [S. 2(28A), 10(37), 45, 56(2)(viii), 145, Land Acquisition Act,1894, S. 28, 34, Art. 300A]

S. 50C : Capital gains-Full value of consideration-Stamp valuation-Transfer of leasehold rights-Provision is applicable in respect of transfer of leasehold rights in the lands which were transferred by the MIDC in favour of the assessee. [S. 2(14)(a), 50C, 260A]

S. 43B : Deductions on actual payment-Provision towards approved gratuity fund-Payment made to LIC gratuity fund approved by the CIT-Deduction allowable-S. 40A(7)(b) being specific provision overrides S. 43B. [S. 40A(7)(b)]

S. 40(ba) : Amounts not deductible-Association of persons-Private specific trust-Interest paid to beneficiaries-Order of Tribunal disallowing the interest is affirmed. [S. 260A]

S. 32 : Depreciation-Written-down value-Block of assets-Amalgamation-Approval of Central Government under S. 72A not required where assessee is not claiming carry forward of unabsorbed depreciation but only adopting correct WDV of amalgamating company’s assets. [S. 2(11), 32(2), 43(6), 72A]