S. 145 : Method of accounting-Estimating profit rate of 15% per cent which was arrived at with consensus between both parties- Addition is held to be justified.

S. 132(4) : Search and seizure-Statement on oath–Addition made on the basis of statement on oath–Subsequent retraction- Statement recorded during the course of action which was in presence of independent witness has overriding effect over the subsequent retraction- Addition is held to be valid. [S. 131, 132, 292C]

S. 92C : Transfer pricing–Arm’s length price–Interest-11.30 per cent interest paid by assessee to its AE was very much within arm’s length rate- Deletion of addition is held to be valid.

S. 80G : Donation-Charitable activities–Application of u/s. 80G(5) cannot be rejected when registration continued. [S. 11AA, 12A, 80G(5)]

S. 54 : Capital gains-Profit on sale of property used for residence-Ownership of land-Housing complex was situated on a piece of land which was occupied by Co-operative Housing Society under a long term lease- Exemption cannot be denied in respect of sale of flat in a society. [S. 45]

S. 37(1) : Business expenditure-Advertisement expenses-Held to be revenue expenditure.

S. 32 : Depreciation-Unabsorbed depreciation-Set off of- Benefit of carry forward and set off of unabsorbed depreciation for assessment year 1997-98 is allowed against income of assessment year 2005-06. [S. 32(2)]

S. 14A : Disallowance of expenditure-Exempt income-Interest free funds were utilized for making exempt investment-No disallowance can be made.[R. 8D].

S. 11 : Property held for charitable purposes-Golf facilities to its members for promotion of sport-No element of activity of being in nature of trade, commerce or business-Interest earned from banks or financial institutions on investment of surplus funds arising from charitable activities was exempted from tax. [S. 2(15)]

S. 11 : Property held for charitable purposes-Educational Institution-Res judicata-Denial of exemption is held to be not justified. [S. 10(23C)(vi), 12AA]