S. 92C : Transfer pricing – Arm’s length price – TNMM – Adjustment in the Manufacturing segment of the assessee- Matter remanded to the Assessing Officer -Claim under section 10A/10B is directed to be allowed on stand alone basis . [ S.10A, 10B ] S. 92C : Transfer pricing – Arm’s length price – TNMM – Adjustment in the Manufacturing segment of the assessee- Matter remanded to the Assessing Officer -Claim under section 10A/10B is directed to be allowed on stand alone basis . [ S.10A, 10B ]

S. 92C : Transfer pricing – Arm’s length price – Service was rendered – Addition was deleted .

S. 80P : Co- operative societies – The activities of the assessee are interlinked with the activities of the primary co-operative societies – Entitle to deduction [ S.80P(2)]

S. 69B : Amounts of investments not fully disclosed in books of account –Burden is on the revenue to prove – Merely on the basis of stamp valuation addition cannot be made . [ S. 45, 48, 50C(2), 69 ]

S. 69 :Unexplained investments – Capital gains – Guidance value – Burden is on revenue – Addition cannot be made merely on the basis of stamp valuation adopted for registration purposes [ S.45, 50C , 142A ]

S. 69 :Unexplained investments – Penny stock –Accommodation entries – Capital gains held to be non genuine – Addition as income from undisclosed source is affirmed [ S.10 (38) , 45 ]

S. 56 : Income from other sources – Purchase of vacant land – Addition on the basis of guideline value – Law cannot operate in vacuum de-horse ground realities which under surrounding circumstances – Amendment is prospective -Addition was deleted. [ S. 50C, 56 (2)(vii)]

S. 40(a)(ii) : Amounts not deductible – Rates or tax – Tax paid abroad – State (local) taxes paid by assessee in countries having DTAA with India which are not eligible for relief under s. 90 or 91 do not attract disallowance under s. 40(a)(ii)- Matter remanded to the Assessing Officer for verification – Commission payment outside India – Not liable to deduct tax at source – Purchase pf software – Matter remanded . [ S. 2(43 ), 9 (1) (vii) 37 (1), 40 (a(ii), 90, 91, 195 ]

S. 32 : Depreciation – Water treatment chemicals, industrial additives- Installation at customers site at free of cost – Disallowance is held to be allowable – Conveyance reimbursement – 5% of disallowance is held to be reasonable [ S.37 (1)]

S. 28(i) : Business loss – Losses incurred on surrender of NLD licence – Allowable as business loss [ S. 35ABB(2) , 37 (1) ]