S. 92C : Transfer pricing-Arm’s length price-Comparables-High degree of brand value-Cannot be comparable.

S. 92C : Transfer pricing-Arm’s length price-Advertising and promotion expenses-Reimbursement of expenses-Adjustment is held to be not valid-Additional evidence-Packaging, design cost-Issue remanded-Depreciation-Good will-Actual cost-Matter remanded. [S. 32, 92CA(3), 234A, 234B, 254(1)]

S. 68 : Cash credits-Cash deposited of sales-Sales cannot be assesse as cash credits-Only gross profit can be estimated-Ad hoc disallowance of 1/5 of expenses is held to be not justified. [S. 37(1), 143(3)]

S. 68 : Cash credits-Identity, genuineness and creditworthiness established-Deletion of addition is held to be justified-Unintended mistakes-Remand report-Deletion of addition is held to be justified. [S. 69C]

S. 56 : Income from other sources-Capital asset-Agricultural land-If agricultural land does not fall in definition of capital asset, difference between district level committee value and sales consideration cannot be brought to tax-Matter remanded. [S. 2(14)(iii), 56(2)(vii)(b)]

S. 56 : Income from other sources-Notional interest-Security deposit-Only incomes falling under deeming provisions explicitly mentioned in Act can be brought to tax-Burden on revenue-Addition was deleted. [S. 4, 22]

S. 56 : Income from other sources-Valuation of shares-Premium on shares-If assessee can substantiate higher value than the Valuation as per Rules higher value should be considered-Matter remanded. [S. 56(2)(viib), R. 11UA]

S. 54F : Capital gains-Investment in a residential house-Purchase of land under four deeds and one land by different sale deed-Merged to single plot-construction of house-Eligible for exemption for entire investment. [S. 45]

S. 45 : Capital gains-Relative occupying a Flat on licence basis-Flat Sold after demise of occupier-Amounts received by assessee as consideration for not interfering in possession of transfer-Not chargeable to tax as capital gains-No transfer of tenancy rights. [S. 48]

S. 43B : Deductions on actual payment-Contribution towards provision for pension fund-Allowable-Provision for leave encashment-Disallowance confirmed. [S. 43B(f)]