S. 92C : Transfer pricing-Arm’s length price-Interest on receivables-Not a separate international transaction-Net margin more than of comparables-Separate Benchmarking not required. Adjustment to be deleted.

S. 92B : Transfer pricing –Arm’s Length Price-Interest free loans to Associated enterprise-Adjustment on account of provision of bank guarantee to associated enterprises-No income earned and commercial expediency not relevant-Adjustment at 0.5% instead of 1.3%.

S. 80IC : Special category States-Industrial Undertaking-Special deduction-Income from undertaking-Interest earned from FDs-Inextricably linked to business activity as maintenance of FDs-Entitled to deduction.

S. 80IC : Special category States-Special deduction-Apportionment of head office expense among eligible units not justified-No nexus with eligible units. [80IB]

S. 80AC : Return to be furnished-Co-operative society-Return to be filed within due date-Failure of-Not entitled to deduction-Adjustments to be made while processing return of income. [S. 80 (P) (2) (a) (i), S. 139 (1), 139 (4), 143 (1) (a)]

S. 69A : Unexplained money-Search and Seizure-Capital gains-On money –Burden of proof-Sale of land-Entry found in software of company whose premises search showing sale of land by assessee-Sale deed was registered much before date of entry found during search-Burden on Assessing Officer to prove assessee received additional “On-Money” Not Discharged-Addition on basis of entry is not sustainable. [S.45,68, 132(4A), 133A]

S. 69A : Unexplained money-Cash deposit during demonetization-Cash from sundry creditors-Not in violation of receiving specified bank notes-Failure by assessee to explain source-Matter Remanded.

S. 69A : Unexplained money-Cash available in old demonetised currency-Withdrawal from bank upto November 8, 2016-Disallowance to that extent not sustainable-Balance disallowance of balance cash proper.

S. 69A : Unexplained money-Compensation on land acquisition-Received on husband’s bank account-withdrawn from and deposited in assessee’s bank account-No material to prove that money utilised for other purpose-Additions to be deleted.

S. 69 : Un explained investments-Search and seizure-Undisclosed income-Seized documents showing receipts and payments-Assessee in real estate business-Cannot be identified whether money used for purchase of land or loan-Profit at 10% to meet end of justice-Seized documents showing receipts and payments-Additions cannot be made on receipts and payments both-Agricultural Income-No evidence of agricultural activity-Receipt cannot be treated as sale of agricultural property-Cash receipts-Declared in original return-Cannot be taxed again in absence of contrary materials. [S. 132]