S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Arm’s Length Price-Most appropriate method-Resale price method is most appropriate method-Comparable-Functionally comparable-Deletion of transfer pricing adjustment is proper.

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax–Corporate guarantee-Corporate guarantee commission to be charged qt 0.50 Per Cent.[S.92CA 92E]

S. 90 : Double taxation relief-Foreign tax credit-Filing of Form 67 with certificates and statements is mandatory-Directory with respective to time-limit-DTAA does not prescribe filing requirement for foreign tax credit it will prevail over provisions of domestic law-Form, certificate and statements filed with return belatedly but before actually processing or before final assessment made is sufficient compliance-Entitled to credit-DTAA-India-USA.[S.6,90A, 91, 139(1) 139(4), R.128(9), Form No 67, Art. 25, 26]

S. 80P : Co-operative societies-Rental income and interest on deposits-Service charges shown as income from other sources-Matter remanded to the file of CIT(A). [S. 22, 24, 56, 57]

S. 69C : Unexplained expenditure-Bogus purchases-Not doubted sales-Estimate of income at 12.5 Per Cent. of bogus purchases is affirmed-As regards special deduction-Industrial undertaking-Matter is remanded. [S.80IC]

S. 69C : Unexplained expenditure-Expenses paid regarding purchase of land prior to withdrawal from bank-Addition as alleged payment out side the books of account-Pending litigation-Advances paid was shown as current liabilities-Addition is not justified.[S.69,69B, 153A]

S. 69 :Unexplained investments-Land purchased in earlier year-Delayed payment-Registered sale without making payment to vendor-Addition cannot be made as undisclosed income.

S. 69 : Unexplained investments-Income from undisclosed sources-Partner in firms carrying construction projects-Entries in Diary seized during search-Cash received and paid-Undisclosed income was disclosed by partners-Deletion of addition is affirmed

S. 69 :Unexplained investments-Cash Credits-unexplained advances-Cash and stock discrepancies-Survey-Retraction-Senior Citizen-Retraction is valid-Shortage of stock-Gross profit rate of 8.02 Per Cent-Statement recorded under Section 131 has no evidentiary value in absence of corroborative evidence-Assessment of disclosed income is invalid-Diary found during survey-Entries giving names and amounts without other details-No inquiry made to establish genuineness of transactions-Addition is not justified-Excess cash found during survey-Addition is affirmed. [S.131, 133A]

S. 69 : Unexplained investments-Unexplained money-Survey-Deeming provision-Statement in the course of survey-Bald allegation of Assessing Officer is not sufficient to consider income declared as unexplained investment-Income offered in the course of survey cannot be assessed as unexplained and has to be assessed as business income. [S. 69A, 115BBE, 133A]