S. 115BBE-Tax on specified income-Determination of tax in certain cases-Unaccounted stock declared during survey-Excess stock being part of total business stock-Cannot be assessed as deemed income [S.69, 69B]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Persistent Loss Filter-Matter remanded-Turnover filter-Companies whose turnover in current year is more than Rs. 200 crores is to be excluded from list of comparables-Companies Lacking Segmental Information And Functionally Dissimilar with assessee cannot be taken as comparables-Interest on outstanding receivables-Matter remanded-Rate of interest charged at Libor + 300 basis points considering credit period of 90 days.[S.92B, 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Turnover filter-Companies having turnover exceeding two hundred crore rupees were to be rejected-Persistent losses filter-Matter remanded-Notional interest on overdue receivables-Transfer Pricing Officer to recompute adjustment only in respect of invoices overdue for more than ninety days at interest rate of six months, Libor plus three hundred and fifty basis points.[R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Selection of comparable-Matter remanded. [R.10B]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Corporate guarantee-International transactions-Guarantee fee at 0.5 Per Cent.is justified-Deduction of tax at source-Matter remanded to the Assessing Officer. [S.92C]

S. 80P : Co-operative societies-Interest-Investment With Co-Operative Banks-Income from other sources-Eligible for deduction of cost for earning of such income-Matter remanded to Assessing Officer for fresh consideration. [S.56, 57(iii),80P(2)(d)]

S. 80P : Co-operative societies-Providing credit to members Eligible for deduction to extent of income earned from facilities extended to its members only-Matter remanded to Assessing Officer-Delay in filing appeal is condoned.[S. 80P(2)(a)(i), 253]

S. 80P: Co-operative societies-Mentioning of status in the return of income as ‘AOP’ as against ‘co-operative society’ would not disentitle the assessee the benefits of deduction claimed u/s. 80P (2)(a)(i) of the Act. [S. 2(31), 80P(2(a)(i), 139, 143(1)]

S. 80IC : Special category States-Fall in gross profit rate-Diversion of profits to subsidiary-May require scrutiny at the hands of the subsidiary under section 80IA (10) and not the Assessee. [S,80IA(10)]

S. 80IA : Infrastructure facility-Search and seizure-claim though not claimed in the original return filed before search-Assessee is entitled to the deduction. [S.80IA(4), 139(1),139(5), 153A]