S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivables-Interest on outstanding receivables from AE-International transaction-60 days and 240 days-The arm’s length interest rate on similar foreign currency receivables/advances is to be taken as LIBOR+200 points. [S.92B]

S. 90 : Double taxation relief-Salary received-Services rendered in Australia-Not taxable in India-DTAA-India-Australia. [S.5, 9(1)(ii) 15, Art. 4(1), 15(1)]

S. 90 :Double taxation relief-Capital gains-Tax residency certificate-Eligible for the benefits of the DTAA in respect of capital gain on the sale of shares of an Indian company and the interest income from compulsorily convertible debentures-DTAA-India-Singapore. [Art. 11, 13]

S. 90 :Double taxation relief-Fees for included services-Support services to achieve standardized IT environment-The amount received by the assessee on account of said services does not fall within the ambit of ‘fee for included services-Not taxable in India DTAA-India-Singapore. [S. 9(1)(vi),9(1)(vii), Art. 12]

S. 80P : Co-operative societies-Providing credit facilities to members-Interest received from members and non-members-Mutuality-If the nominal/associate members of the assessee society are not members and they are not entitled to share of profits earned by the assessee, then proportionate deduction under s. 80P(2)(a)(i) is to be granted in respect of interest earned by providing credit facilities only to the regular members; issue is remitted to the AO for afresh consideration.[S.57(iii), 80P(2)(a)(i), 80P(2)(d)]

S. 80G : Donation-Tata Institute of Social Sciences-Approved university or educational institution as per notification dt. 15th Dec., 1993-Order of CIT(A) restoring the matter back to the AO to grant deduction to the assessee under s. 80G to the extent of 50 per cent of donation is affirmed. [S.80G(2)(a)(iiif), 80G(4)]

S. 69C: Unexplained expenditure-Unrecorded purchases from foreign supplier-No supporting documents-Addition is affirmed.

S. 69A : Unexplained money-Cash deposited in the bank-Charitable society-PAN of chairman-Addition is deleted. [271AAC]

S. 69A : Unexplained money-Search and seizure-Gold found during search-1300 grams-Status of family-Addition is deleted. [S. 132]

S. 69A : Unexplained money-Cash deposits-Cash withdrawn earlier-Addition is deleted.