S. 92C : Transfer pricing—Comparables—Functionally indifferent companies cannot be selected as good comparable-Asset management company cannot be compared with market support services.

S. 92C : Transfer pricing–Arm’s length price–Notional interest– Loan to AE–Estimate of interest at 11% was held to be not valid when the assessee had charged the interest at 8%-Rule of consistency is followed–Bench mark transaction-Cup method–Adjustment made was deleted–Ad hoc method cannot be applied. [S. 92CA] .

S. 69C : Unexplained expenditure-Bogus Purchases-Raw material-Survey-Letters were issued to the purchasers after five years of end of assessment year-purchasers are witness of department and did not turn of for cross examination- Inspectors report was not confronted to the assessee- Deletion of addition was held to be justified. [S. 133A, 143(3), 145]

S. 69 : Unexplained investment –Undisclosed income-Merely on the basis of AIR information and ITS data addition cannot be made. [S.131, 133(6), 143(3)]

S. 44BBB : Foreign companies-Civil construction-Turnkey power projects -Books of account maintained–Applicability of presumptive taxation cannot be thrust upon the assessee.[ S.44AA, 44AB, 44BBB,145 (3)]

S. 40(a)(ia) : Amounts not deductible-Deduction at source– Interest–Commission–Brokerage-Insurance commission–Reinsurance premium from various insurance companies–Not liable to deduct tax at source.[S. 194D]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident–Reimbursement of expenses–Not liable to deduct tax at sources.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Re-insurance Premium—Liable to deduct tax at source– Disallowance is held to be justified.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident–No business connection in India–Reimbursement of expenses–Matter remanded-DTAA-India–Bangladesh-Nepal.

S. 37(1) : Business expenditure—Payment to motor car dealers- Genuineness of payment was not in doubt- Disallowances cannot be made.