S. 234D: Interest on excess refund – No additional interest had been computed under S. 234D in the reassessment proceedings and therefore interest is chargeable.

S. 147 : Reassessment – Issue was not examined during assessment hence reassessment was held to be valid. [ S.194H ]

S. 115JA : Book profits – Not applicable to Banking company

S. 92C : Transfer Pricing – Most appropriate method -Back to back transactions and solitary transaction-Matter restored to TPO .

S. 54 : Capital gains – Profit on sale of property used for residence – Mere availment of house building loan by assessee from bank for purchasing a new residential unit could not act as a disqualification for claim of exemption .[ S.45 ]

S. 50C : Capital gains – Full value of consideration – Stamp valuation – Assessee could raise objection to valuation through his return of income, only in the assessment proceedings . No universal principle with regard to being heard in the matter can be laid down and it all depends upon the language of provision and object and purpose of it [ S.45 ]

S. 45 : Capital gains –Business income- Sale of shares – Following the rule of consistency, the income from sale of shares is assessable as capital gains and not as business income. [ S.28(i) ]

S. 40A(2): Expenses or payments not deductible – Excessive or unreasonable –Firm -Partner- When partners of the firm contribute land as stock in trade though provision of S.45(3) would not be applicable , AO can examine reasonableness of payment to partners [ S.45(3) ]

S.40(a)(ia):Amounts not deductible – Deduction at source – Purchase of raw materials- Not liable to deduct tax at source [S.194C ]

S. 40(a)(i) : Amounts not deductible – Deduction at source -Non-resident –Professional fees paid to foreign company to know about tax law applicable in that Country could not be taxed in India as per Art 14 of the OECD Model Tax Convention hence not liable to deduct tax at source.