S. 92C : Transfer pricing-Arm’s length price-ITES services did not form a single composite transaction-Transactions cannot be aggregated-Extended credit period-Addition of notional interest is held to be not justified.

S. 92C : Transfer pricing-Arm’s length price-Loan and advance-Interest-CUP method-Reimbursement of expenses-No adjustment can be made-Corporate guarantee was extended by assessee as a shareholder activity-No adjustment can be made. [S. 92B]

S. 80P : Co-operative societies-Deposit from members-Assessing Officer passing the order, without verifying the licence to carryon banking business-Matter remanded to the Assessing Officer. [S. 80P(2)(a)(i)]

S. 69A : Unexplained investment-Jewellery-Weight of jewellery allowed as per instruction No 1916, dt. 11-5-1994 need not be explained-Addition cannot be made-Over and above the quantity of the jewellery has been explained, no addition can be made.

S. 68 : Cash credits-Share capital-Mere submission of name and address of creditor, income tax returns, balance sheet/statement of affairs of creditor and bank statement of creditor is not sufficient.

S. 68 : Cash credits-Cash deposited-Bank-Sale of Agricultural land-Gift-Failed to show the creditworthiness-Addition is held to be justified-Enhancement without giving an opportunity of hearing is held to be bad in law. [S. 251]

S. 64 : Clubbing of income-Spouse-Wife invested gifted amount in business of Futures and Options (F&O)-Loss incurred by wife is Liable to be clubbed in hands of assessee for the purpose of set off. [S. 64 (1)(iv)]

S. 56 : Income from other sources-Compensation from Tenant for not letting out two units without the consent-Assessable as income from other sources and not as income from house property. [S. 22, 23]

S. 50C : Capital gains-Full value of consideration-Stamp valuation-Lease hold rights-99 years lease-Provision is not applicable-Addition is deleted. [S. 45, 48, Wealth-tax Act, 1957, S. 5(1)(xxxii)]

S. 45 : Capital gains-Foreign Institutional Investor (FII)-Income deemed to accrue or arise in India-Status of beneficiaries or constituents of tax transparent entities is relevant for purpose of determining treaty protection to trustee in representative capacity-Capital gains, on sale of shares in hands of assessee and investors, it represents as trustee, were treaty protected from taxation in India. DTAA-India Netherlands. [S. 9(1)(i), Art. 13]