S. 2(22)(e) : Deemed dividend –Loan to share holder -Holding more than 10 per cent of equity shares of lending company and also having substantial interest in borrowing company- Amount of loan given by lender company to borrower company is held to be assessable as deemed dividend.

S. 4 : Charge of income-tax – Forfeited amount cannot be assessed as income – Justified in reducing the said amount from cost of the land [ .S.51]

S. 271(1)(c) : Penalty – Concealment – Transfer pricing study report from an outside expert not called in question – Penalty cannot be levied by invoking Explanation 7 to s. 271(1)(c).

S. 271(1)(c) : Penalty – Concealment – Penalty is not leviable where the AO has failed to mention the specific charge for levy of penalty in the show cause notice under section 274 of the Act. [S. 274]

S. 253 : Appellate Tribunal – Power to admit additional grounds – Revenue once accepted claim during assessment cannot raise additional ground which was not a subject matter appeal before lower authorities.

S. 253 : Appellate Tribunal – Delay of 658 days in filing of appeal – Employee failed to deliver the order of the CIT(A) to the CA for necessary action – Delay caused due to bonafide mistake of employee – Delay condoned – Initiated vide notice dated 23.09.2003 but the respective orders were passed on 28.03.2011 which were beyond a period of one year from the end of the financial year in which the proceedings u/s. 201 of the Act were initiated-orders passed u/s. 201(1)/201(1A) of the Act, were barred by limitation.[S.194C,201(1) ,201(IA)]

S. 249 : Appeal – Commissioner (Appeals) – Form of appeal and limitation – Delay in filing of appeal electronically was to be condoned by CIT(A) where such delay was caused due to technical issues and lack of knowledge regarding e-filing procedure.

S. 145 : Method of Accounting – Rejection of books – AO has to specify defects, non-compliance of accounting standards.

S. 143(3) : Assessment- Overdue interest-Provisions for bad and doubtful debts – Schedule bank – Interest income on NPAs is taxable on receipt basis and not on accrual basis. [S.4,28(i), 36, 37 (1)]

S. 92C : Transfer pricing – Arms’ length price – Profit Split Method can be adopted as most appropriate method in cases involving multiple inter-related international transactions which cannot be evaluated separately.