S. 115JB : Book profit-Electricity Company-Company engaged in generation and supply of electricity-Not required to prepare its profit and loss account and balance sheet as per Parts II and III of Schedule VI of Companies Act-Provision of book profit not applicable.

S. 92C : Transfer pricing-Arm’s length price-Foreign comparables-Guidance note by ICAI and transfer pricing guidelines issued by OECD do not prohibit foreign AE to be a tested party-Foreign AE could be selected as a tested party-Where segmental results are available, adjustment can be made only on basis of individual transaction and not on aggregation basis. [S. 92E]

S. 80IA : Industrial undertakings-Infrastructure development-Electricity distribution-Expenditure on network of a new transmission or distribution line-No requirement of capitalization of said expenditure in books of account-Deduction allowable. [S. 800IA(4)(iv)]

S. 69B : Amounts of investments not fully disclosed in books of account- Assessment-Stock-Value of stock shown in stock statement as on 28-3-2005 submitted to bank was far in excess to value of stock shown in audit report for period ending 31-3-2005-No explanation was offered-Order of Tribunal was affirmed. [S. 143(3),145]

S. 69 : Unexplained investments-Search and Seizure-Seizure of Jewellery-Consignee-Payments were accounted-Addition was held to be not justified-Directed to release of seized jewellery. [S. 132. 153C, Art. 226]

S. 69 : Unexplained investments-Recorded in the books of account-Deletion of addition is held to be valid.

S. 68 : Cash credits-Shares of Raj Darbar Group brought back the shares at much lower rate at which the shares were allotted-Addition was made not on the basis of seized materials or statements-Deletion is held to be justified. [S. 132, 153C]

S. 68 : Cash credits-Unsecured loans-Established genuineness and credit worthiness-Deletion of addition was justified.

S. 68 : Cash credits-Reconciliation of statement-Supported by evidence-Order of Tribunal was affirmed. [S. 260A]

S. 48 : Capital gains-Sale consideration-Fair market value deemed to be full value of consideration in certain shares-Transfer of a plot of land-Joint Development agreement-Not ascertainable-Guidance value of land would be appropriate mode to determine full value of consideration-Provision of section 50D came in to force with effect from 1-4-2013 is not applicable for the year under consideration. [S. 45, 50D]