S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-An investment advisor or sub-advisory cannot be compared with a merchant banker or investment banker-Tribunal’s finding based on decision of Supreme Court-No question of law. [S. 260A]

S. 69C : Unexplained expenditure-Bogus purchases-Accommodation entries-Civil contract work-Municipal Corporation of greater Mumbai-Information received from the Sales Tax Department through the Director General (Inv)-Purchases through banking channels-Disallowance restricted to profit element-Order of Tribunal affirmed. [S. 143(3), 260A]

S. 10B : Export oriented undertakings-Deduction and not exemption-Set off of losses-Loss from export oriented undertakings-Can be set off against other business income-Payment of management fees-Transfer pricing adjustment-Closing stock addition-Provision for absolute inventory-Valuation of stock on scientific basis-Question of fact. [S. 70, 71, , 92C,260A]

S. 4 : Charge of income-tax-Loss of source of income-The amount received under the deed for restrictive covenant as a capital receipt not liable to tax. [S. 7(1)(iv), 17(3)(i), 28(va), Art. 226]

S. 145 : Method of accounting – Estimation of income – Discrepancy in receipt shown in 26AS – Merely on the basis of difference addition cannot be made [ S. 68, 133(6) , Form No 26AS ]

S. 80IB: Industrial undertakings – Form No 10CCB was uploaded on receipt of intimation – Assessing Officer is directed to allow the rectification applied by the assessee and allow the claim. [ S. 143(1), 154 ]

S. 260A : Appeal – High Court -Territorial jurisdiction —The High Court having jurisdiction over the Assessing Officer who passed assessment order – Appeals against orders of Appellate Tribunal lie before High Court within whose jurisdiction assessing officer who passed assessment order situated. [ 116, 120, 124, 127, 252, 255, 260A, 269]

S. 201 : Deduction at source – Failure to deduct or pay – Leave travel concession — Estimate of income – Assessee in default Public sector Bank — Employees travelling not only to domestic destination but to foreign countries – Not taking shortest possible route — Employees not entitled to exemption — Leave travel concession reimbursed without deduction of tax at source —Assessee could not claim ignorance about travel plans of employees- Complete facts available- Not a bona fide mistake-Liable to pay interest . [ S. 10(5), 192(1) ,201(1), ITR . 2B]

S. 139 : Return of Income – Income tax returns do not necessarily furnish an accurate guide of the real income- Particularly, when parties are engaged in a matrimonial conflict- High Court was not justified in setting aside the order of the Family Court . [ Code of Criminal Procedure 1973 , S. 125 ]

S. 220 : Collection and recovery – Assessee deemed in default – Interest mandatory — Delay in payment of tax — Waiver — No genuine hardship- Raising dispute before Authority not ground for waiver of interest — Dispute pending resolved under mutual agreement procedure – Order of Commissioner refusing to waive interest is justified. [ S. 220(2), 220(2A) ]