S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-comparables-There is no error in the reasons given by the TPO/DRP to include L&T in the final set of comparables-PLR-Interest on outstanding receivable-TPO is directed to adopt appropriate rate of interest by considering the currency in which the outstanding receivable by the assessee and its AE. [S.92B]

S. 80G : Donation-Time-limit for filing application for final approval-Form No. 10AB was filed on 23rd Sept., 2023 was well within time i.e., within six months prior to the expiry of the period of provisional approval-Order of the CIT(E) is set aside with direction to pass a fresh order on merits as provided in law. [S.12A(1)(ac)(vi), 80G(5)(iii)]

S. 80G : Donation-Time-limit for filing application for final approval-Existing Trust or institution-Applied for permanent registration under S. 80G before the expiry of provisional approval-The application of the assessee was not time-barred-The order under s. 80G is set aside to CIT(E) for de novo adjudication-Speech of the Finance Minster is relevant. [S.12AB, 80G(5)]

S. 69A : Unexplained money-Cash deposits-Demonetization-Petrol pump-Not violated any provision of law or any Government guidelines-Addition is deleted.

S. 69A : Unexplained money-Cash deposit-Demonetization-Sufficient stock-Sales-Sales shown in VAT return-Addition is deleted.

S. 69A : Unexplained money-Demonetisation-Bank notes-Complete record is maintained-Receipts from the customers cannot be assssed as unexplained.

S. 68 : Cash credits-Brokerage on sales-Cannot be considered ad bogus-Books of account not rejected-Recovery from debtor-Advance given in earlier years-Cannot be assessed as cash credits-Business advances-Confirmations filed-Short term advances-Leger account and bank statement is filed-Cannot be assessed as cash credits-Payment made to purchase of goods-Not assessable as cash credits-Credit sales-Cannot be assessed as cash credits.

S. 68 : Cash credits-Loan-Produced confirmation, PANs, bank statements and acknowledgements of IT returns of the lenders-Addition is deleted.

S. 68 : Cash credits-Long tern capital gains-Sale of shares-Penny stock-General report of investigation wing-UD Ltd-Consideration received through online trading through BSE platform-Shares have been credited in the demat account and transferred out of demat account at the time of sale-Denial of exemption is not justified-Sale consideration cannot be assessed as cash credits.[S 10(38), 45, 68 69C]

S. 68 : Cash credits-Share application money-Filed copy of PAN card, share application form, allotment advices, relevant bank statements, returns for the relevant assessment year, audited financial statements, etc-Established identity and creditworthiness-Summons complied with-Reply to notice u/s 133(6)-Order of CIT(A) deleting the addition is affirmed. [S. 131, 133(6)]