S. 133A : Power of survey-Closing stock-Carry forward and set off-Enhanced value of stock shown in the books of account which was found in the course of survey-Entitle to set off of closing stock. [S. 145]

S. 133A : Power of survey-Income from undisclosed source-Unaccounted professional income-Double addition-Followed order of Settlement Commission-Deletion of addition is held to be justified. [S. 245D(4)]

S. 133A : Power of survey-Undisclosed income-Real Estate business-Income declared in the course of survey-Earlier losses and current year loss can be set off against income disclosed in the course of survey. [S. 28(i), 72]

S. 92C : Transfer pricing-Arm’s length price-Selection of comparable-Consulting business-Companies rendering soft ware services cannot be comparable.

S. 92C : Transfer pricing-Arm’s length price-Advance Pricing Agreement-Order of CIT(A) on the basis of Advance Pricing Agreement is held to be proper.

S. 92C : Transfer pricing-Arm’s length price-Rule of consistency No distinguishing facts in Current year-Addition on account of advertisement, marketing and sales promotion expenses not sustainable. [S. 143(3)]

S. 92C : Transfer pricing-Arm’s length price-Functionally dissimilar companies cannot be taken as comparable-Outstanding receivable-Debt free company-Adjustment made on interest on receivables not sustainable-Appellate Tribunal-Additional ground admitted-Education cess-Allowable as deduction. [S. 37(1), 40(a)(ii)]

S. 92C : Transfer pricing-Arm’s length price-Adjustment was made on the basis of Location saving-Matter remanded-Inter group services-Justified in making the adjustment. [S. 92B]

S. 92C : Transfer pricing-Arm’s length price-Raw material from related parties-Arithmetical Mean Rate-Lowest or minimum rate-Deletion of addition is held to be justified. [S. 92C(2)]

S. 80IC : Special category States-Substantial expansion-Initial assessment year-Previous year in which substantial expansion undertaken would became initial assessment year-Entitled to 100 Per Cent. deduction from that assessment year subject to maximum period of ten years.