S. 115BBE : Tax on specified income-Income from undisclosed Sources-Bogus purchases-Construction business-Confessional statement by suppliers-Accommodation entries of Bill trading without any supply of materials-Failure to file necessary evidence in support of purchases-Addition is justified.
S. 115BBE : Tax on specified income-Search-Unexplained expenditure-Diagnostic Centre-Additional income offered as business income-Referral fees-Unaccounted expenditure-additional income cannot be taxed at special rate-Current years loss is allowed to be set off-Reasons recorded cannot be based on conjectures and surmises. [S. 69C, 153A]
S.115BBE : Tax on specified income-Cash credits-Collection found recorded in notebook pertaining to business-Directed to be treated as business income and not as cash credits [S. 68, 69 69A, 69B]
S. 115BBC : Anonymous donations-Details of donors with names address and confirmation letters provided-Mere absence of PAN the donations cannot be assessed as anonymous donations.[S. 13]
S. 92CA : Reference to Transfer Pricing Officer-Guidelines issued by CBDT-Adjustment of more than 10 crores or more-No adjustment of more than 10 crores in the case of assessee-Reference made to TPO not valid-Subsequent order passed by TPO not sustainable-[S. 92C]]
S. 92C : Transfer pricing-Arm’s length price-Bright Line Test (BLT) AMP expenses-TPO was not justified in holding that by incurring AMP expenditures assessee had promoted brand and marketing intangible of its overseas AE and, thus, it had to be treated as international transaction. [S. 92B]
S. 92C : Transfer pricing-Arm’s length price-Guarantee arrangements, arm’s length guarantee commission charge should be restricted at 0.5 per cent of guaranteed amount-Adjustment of purchases-Eligible and non-eligible units-Downward adjustment was held to be not valid [S. 80IA(10), 92CA]
S. 92C : Transfer pricing-Arm’s length price-CUP method-Matter remanded.
S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee-ALP adjustment on account of corporate guarantee restricted to 0.35%. [
S. 92C : Transfer pricing-Arm’s length price-Guarantee commission-Directed to compute TP adjustment at the rate of 0.5 percent.