S. 92C : Transfer pricing-Comparable—Functionally different activities cannot be taken for determination of Arm’s length price.

S. 92C : Transfer pricing–Comparable–Functionally indifferent companies cannot be selected as comparables. [S.260A ]

S. 80IB : Industrial undertakings–Contract for manufacturing of product-Manufacturing activity undertaken by that other entity for and on behalf of Assessee was not under its direct supervision and control –Not entitle to deduction.

S. 80HHE : Export business-Computer software-Claim was not made when the return was filed-Claim was made when the amount was received–Entitle to deduction.

S. 69C : Unexplained expenditure-Bogus purchases-Estimate of GP from 15% to 12% by the Tribunal is held to be justified.

S. 68 : Cash credits-Variation in closing balance in bank statement and debit balance in books Income—Advance received- Not proved satisfactorily–Addition is held to be justified.

S. 68 : Cash credits-Share Capital—Survey – Bogus accommodation bills to various concerns including assessee and its sister companies—PAN no – Affidavit of investors- Acknowledgement of filing of return -Deletion of addition by the Tribunal is held to be justified.

S. 68 : Cash credits – Share capital- Most of the address of share holders are identical-They could not be traced despite issue of notice u/s 131 of the Act –Affidavits are similarly worded- .Addition is held to be justified. [S. 131]

S. 45 : Capital gains–Long term capital gains-Firm-Retirement- Amount received by retiring partner as good will is held to be not taxable as capital gains.

S. 36(1)(ii) : Bonus or commission- Directors and employees- payment of bonus was part of employment agreement and it was a performance based payment—Allowable as deduction.