S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-TPO ought to have arrived at ALP of assessee’s sale to its AE by only comparing it with uncontrolled transaction of sale-SLP of Revenue is dismissed.[S. 92, Art. 136]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest-Net monthly balance payable-Justified in not charging interest in delayed payments to non-AEs-SLP of Revenue is dismissed.[Art. 136]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Determination of ALP by Tribunal can be subjected to scrutiny by High Court in an appeal-Matter remanded to High Court. [Art. 136]
S. 80P : Co-operative societies-An apex co-operative society within meaning of State Act, 1984-Primary object is to provide financial accommodation to its members who were all other co-operative societies and not members of public-Not a co-operative Bank-Entitle to deduction. [S.80P(2)(a)(i), 80P(4), Banking Regulation Act, 1949, S.56, Kerala Co-operative Societies Act, 1969]
S. 80IB(10) : Housing projects-Sepaarate completion certificate to each unit-Eligible for deduction. [S.260A]
S. 80IA : Industrial undertakings-Infrastructure development-Market value of electricity supplied by CPP Unit to general unit would be same being charged by GEB from consumers and it ignored rate on which power generating company supplied its power to GEB.[S.80IA(8)]
S. 69 : Unexplained investments-Undisclosed liability-Deletion of addition by the Tribunal is affirmed. [S.69A, 69B, 69C, 132]
S. 69 : Unexplained investments-Capital-Loan-No incriminating material was found-Block assessment order-Deletion of addition by the Tribunal is affirmed by the High Court on merit. [S. 68, 148, 260A]
S. 68 : Cash credits-Settlement Commission-Undisclosed income-Bogus share capital-Undisclosed income taxed in the assessment of flagship company-Deletion of addition by the Tribunal is affirmed. [S. 132(4), 245D, 260A]
S. 56 : Income from other sources-Valuation of shares-Book value of assets-.Formula adopted by the Assessing Officer is not applicable to the relevant assessment year-Order of Tribunal deleting the addition is affirmed by the High Court. [S. 56(2)(viib), R.11UA]