S. 92C : Transfer pricing – Arm’s length price – Comparable- Software testing services company — Company rendering whole basket services — Company providing software services to its clients — Not Comparables.

S. 92C : Transfer pricing – Arm’s length price – Foreign exchange gain or loss- Comparable- Comparability position on year to year basis independently to be examined – Provision for doubtful debts . [ S.92CA ]

S. 92C : Transfer pricing – Arm’s length price -Shipping business- Tonnage taxation scheme – Interest on purchase of two ships- No application of transfer pricing provisions to income covered under tonnage tax scheme – Guarantee commission- Assessing Officer is directed to make adjustment by applying 0.25 Per Cent. To Transaction Instead of 0.5 Per Cent- Advance to share application money – Shares not allotted -Full money refunded- loan – Rate of interest to be applied on amount at Libor- Service agreement – Interest to be confined up to end of year and not thereafter.

S. 80IB(10) : Housing projects- Completion certificate is not obtained for certain flats —Not entitled to deduction in respect of those flats — Development plan road acquired by Municipal Corporation not be reduced from total land area of project.

S. 69C : Unexplained expenditure -Bogus purchases – Sales not doubted – Quantitative tally of purchases of meat and exports furnished – Addition is held to be not justified .

S. 68 : Cash credits – Share premium — Identity and creditworthiness of share holders and genuineness transaction is not doubted – Merely for not furnishing the valuation report -Addition is held to be not justified .

S. 49 : Capital gains – Previous owner – Cost of acquisition –Financial asset – Period of holding -Brand name – Transfer of intangible assets with right to carry on business – Holding period should be determined including period of holding of previous owner, ie. Amalgamating Company-No transfer taking place on appointed date of Amalgamation — Period of holding more than 36 months — Receipt taxable as long-term capital gains [ S. 2(11) ,2(42A) , 45, 49 (1), 55(2)(a)(ii) ]

S. 37(1) : Business expenditure -Capital or revenue – One time lease rental charges for 90 years – One-Ninetieth of amount paid allowable as revenue expenses and balance to be treated as pre paid advance rent .

S.37(1): Business expenditure -Capital or revenue – Expenditure on setting up of new outlets an expansion of existing business — Expenditure on salary and conveyance allowable as revenue in nature.

S.37(1): Business Expenditure — Interest for delayed payment of pole rental charges- liability crystallised during the year -Not prior period expenses but compensatory in nature — Allowable as deduction . [ S.145 ]