S. 92C : Transfer pricing – Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Principle of natural justice-Notice and grant of approval by Principal Commissioner quashed and set aside-Matter remanded to Assessing Officer for considering matter afresh after hearing assessee and thereafter to pass speaking order.[S.92CA(1), 92CA(2), 92CA(3), Art. 226]

S. 69A : Unexplained money-Post-demonetisation deposit of old currency notes-Cash book balance insufficient to explain deposit – Failure to explain the source – Addition was affirmed.[S. 260A]

S. 69A : Unexplained money – Denominations – Details not maintained – Nature of source of cash deposit was not explained satisfactorily – SLP of assessee dismissed. [Art. 136]

S. 45 : Capital gains-Accepted cost of acquisition – Difference between intrinsic value of shares and amount paid by assessee cannot be taxed as perquisites – Order of Tribunal deleting the addition is affirmed. [S. 2(24)(iv), 260A]

S. 40A(3) :Expenses or payments not deductible-Cash payments exceeding prescribed limits-Payments to agents cannot be disallowed – Order of Tribunal set aside. [ITR, 1962 R. 6DD, Indian Contract Act, 1872, S. 182.]

S. 37(1) : Business expenditure-Foreign exchange rates Expenses incurred on account of foreign exchange fluctuation and interest thereon in respect of foreign currency loans-Allowable business expenditure-Order of Tribunal set aside-Travelling expenses-Expenses incurred towards foreign tour of executives accompanied by their spouses-Major portion of claim allowed by Commissioner (Appeals)-Miniscule amount being involved order of Tribunal, affirmed.

S. 37(1) : Business expenditure-Provision for warranty – Deletion of addition by the Tribunal is affirmed.

S. 119 : Central Board of Direct Taxes- Circular – Condonation of delay – Filing of return of loss – Genuine hardship – Delay of 5 months in filing return due to bona fide professional advice by Chartered Accountant – Assessee should not suffer grave hardship for a professional’s mistake – Circular No. 9 of 2015 – Delay was condoned – CBDT’s rejection order set aside- Directed that the return filed on 30th March 2019 be treated as filed in time, and permitted assessment to be completed under section 153(1B) of the Act . [S. 72, 80, 119(2)(b), 139(1), 139(3), 153(1B), Art. 226 ]

S. 147 : Reassessment – Information from third-party search – Accommodation entries – Cash credits -Section 153C not triggered, reopening u/s 147 is valid-On merits, addition based mainly on untested third-party statement without cross-examination requires fresh adjudication by CIT(A). [S. 68, 132(4), 133(6), 148, 151, 153C, ITAT Rule, 1963 ,R. 27]

S.115BAA : Tax on income of certain domestic companies – Determination of tax in certain cases – Option exercised under section 115BAA – Rate of tax applicable – Long term capital gains – Company opting for taxation under section 115BAA is liable to pay tax at 22% on total income including long-term capital gains and not at 20% as per section 112. [S. 45 , 112, 143(1), Form 10IC ]