S. 92C : Transfer pricing -Arm’s length price-Avoidance of tax-International transaction-Selection of comparables -Companies engaged in diversified activities without segmental results-Functionally not comparable –Addition was deleted. [S.92CA]

S. 92C: Transfer pricing -Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-No estoppel-Assessee is not estopped from seeking exclusion of company originally selected in TP study.[S.92CA]

S. 92B: Transfer pricing -International transaction-Arm’s length price-Avoidance of tax-Lending or Borrowing / Capital Financing-Delay in receipt of receivables beyond a reasonable credit period partakes the character of an advance and results in an international transaction in view of the Explanation to section 92B(2), which can thereafter be subjected to computation of notional interest. [S. 92C]

S. 80G: Donation-Approval -Application for final approval -Application filed six months before expiry of provisional approval -Within limitation. General principles-Rules of procedure are intended to advance justice-Tribunal quashed the order and restored the matter to the CIT E) to consider the application on merits after granting an effective opportunity of hearing. [S.80G(5)]

S. 80G: Donation-Approval -Application under wrong sub-clause -Curable defect -Commissioner (Exemptions) must permit rectification -Approval cannot be denied for technical error-Duty of Officers to assist assesses in obtaining relief to which assessee entitled-CBDT Circular No. 14 (XL-35), dated 11-4-1955 [S.12A, 80G(5) S. 119)]

S. 69C: Unexplained expenditure-AO treated two purchase parties as bogus and made 100% disallowance-Bhawarlal Jain group-Since sales had not been doubted and without purchases, there cannot be any sales, no adverse inference could be made insofar as the export of diamonds was concerned, for which all documentary evidence was placed on record-Addition was restricted to profit element. [S. 69C, 133A, 148]

S. 69: Unexplained investments-Unexplained money -Cash deposits -Advance received under unregistered agreement to sell-Addition was deleted-Agricultural income accepted as explained sources-Addition was deleted. [Indian Registration Act, 1908, S. 17]

S. 68: Cash credits -Interest on loans -No disallowance when assessee proves identity, creditworthiness and genuineness of lenders and loans accepted by Revenue-Addition was deleted. [S. 37(1)]

S. 68 : Cash credits -Burden of proof -Share application money -Assessee filing documents such as income-tax returns, confirmations, bank statements, income-tax notices and assessment orders of share applicants -Assessing Officer not making independent enquiry or calling for particulars from parties who advanced money -Addition was deleted.

S. 68: Cash credits-Loose sheets / Excel sheets found during search -No corroborative evidence -A seized loose sheet or Excel sheet, by itself, cannot justify additions under sections 68 or 69C unless the Revenue establishes ownership of the document, its nexus with the assessee, and corroborates the entries with independent evidence. Documents must be read in their entirety and not selectively. Additions were deleted.[S.69C, 115BBE]