S. 92C : Transfer pricing – Arms’ length price – Assessee company processed, bottled and sold liquor in India under two segments Bottled in India Scotch (BIIS) and India Made Foreign Liquor (IMFL) – activities of the assessee are two different segments – assessee’s segregation approach for benchmarking these segments justified.

S. 92C : Transfer pricing -Arm’s length price- Matter was remanded .

S. 92C:Transfer pricing – Non-charging or under-charging of interest on excess period of credit allowed to AE for realization of invoices amounts to an international transaction and ALP of such an international transaction is required to be determined .

S. 80IB :Industrial undertakings – Manufacture- Conversion of 24 Karat Gold into 22 Karat Gold ornament amounts to manufacturing.[ S.2(29BA)]

S. 80IA: Industrial undertaking – Survey- Bogus purchases-Additional income offered as non genuine purchases -Entitle deduction [ S.80IA(4), 133A ,147 ]

S. 80IA : Industrial undertakings – Infrastructure Development – Joint venture between two companies Merely because assessee was paid by Government for development work, it could not be denied deduction u/s 80IA(4) when it provided a complete infrastructure required to support the development of infrastructure facility and deployed its various resources and exposed itself to various risks. [ S.80IA(3), 194C ]

S. 79 : Carry forward and set off losses – Change in share holdings – Companies which public are not substantial interested – Unabsorbed depreciation-Business loss was not allowed to be carried forward for the AY. 2007 -08 to 2010-11 [ S.32 ]

S. 69C : Unexplained expenditure -Bogus purchases – Payments were made to suppliers through banking channels – Paintings were reflected as a part of closing stock – Addition is held to be not justified.

S. 69: Income from undisclosed sources — Unexplained investments -Gross profit is higher than earlier years -Additions cannot be made

S. 68: Cash credits- Unsecured loan- Furnished names and addresses of concerned parties, their PAN and confirmation with bank account and their Income tax returns, and AO had not carried out any investigation to show that those companies did not exist but were paper companies- Addition cannot be made . [ S.131 ]