S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Allocation of common expenses-Allocation done by the TPO on the basis of revenues from the two segments is in order-Adjustment on account of payment of customs duty-No adjustment is allowable on account of the fact that the assessee has paid more customs duty than that paid by the comparables-Most appropriate method-TNMM should be applied in respect of international transaction of sale of finished goods.

S. 80P : Co-operative societies-Interest received from Baroda Rajasthan Gramin Bank Ltd. being a regional rural bank is not a cooperative society-Not entitle to deduction-Interest from central co-operative bank is eligible deduction-Circular No. 6 of 2010, dt. 20th Sept., 2010. [S.80P(2)(d)]

S. 80IA : Industrial undertakings-Qua undertaking and not Qua assessee-Enterprises engaged in infrastructure development-Entire undertaking which developed the industrial park has been transferred-Transfer of undertaking-of Transferee is entitled to deduction-Circular No 799 dt 14-9-1999-Interest on fixed deposits-Not eligible deduction u/s 80IA-Assessable as income from other sources-Interest expenditure for earning of interest is allowable as deduction. [S.56 57(iii), 80IA(4)(iii), 80IA(12) ]

S. 80G : Donation-Provisional registration-Time for filing application for regular registration-Words “or within six months of commencement of its activities, whichever is earlier”-The provisional approval is effective up to assessment year 2025-26-Directed to treat the application as filed within statutory and allow approval as per the law. [S.80G(5)]

S. 69C: Unexplained expenditure-Bogus purchases-Disallowance is restricted to 10 percent of alleged bogus purchases-Reassessment is valid-Sanction-Sanction granted by Principal CIT is valid.[S. 147, 148, 151]

S. 69 :Unexplained investments Undisclosed sources-Survey-Stock-Additional income surrendered during survey-Income surrendered during the course of survey cannot be brought to tax under the deeming provisions of S 69 and 69A of the Act-Assessable as business income-Provision of section 115BBE cannot be applied. [S. 28(i), 69A, 115BBE, 133A]

S. 69A : Unexplained money-Deposits-Bank account-Non-Resident-Demonetisation-Amount received on cancellation of reservation of hotel booking-Addition is deleted.

S. 69 :Unexplained investments-Cash deposits-Investment in company is not explained-Investment is property-Not substantiated-Addition is affirmed-Sale of shares-Less than fair market value-Income from other sources-Difference in market value is taxed-Deduction is allowed to the extent addition confirmed of unexplained bank deposits. [S. 45, 56(2)(vii)(c)]

S. 68 : Cash credits-Share application-Substantial creditworthiness-Mere non-appearance of directors addition is not justified.

S. 68 : Cash credits-Capital gains-Penny stock-Information from Investigation Wing-Purchase of shares of LLDP Ltd at Rs. 6 per share-Sold at Rs 283 per share after 19 months-Non genuine-Exemption denied-Assessed as income from undisclosed source. [S. 10(38) 45, 69]