S. 115JB : Book profits – Non-Resident — Preparation of accounts under Special Acts — Minimum Alternate tax Provisions was held to be not applicable.

S.115JB:Book profits – Depreciation-AO has no power to make adjustment other than the adjustment as provided in Explantion1

S. 115JB : Book profits – Exempt income – Disallowance under section 14A can be invoked while computing book profit is a question of law [ S.14A, 260A ]

S. 115BBC : Anonymous donations – Donor denied having given any donation to trust hence addition was held to be justified [ S. 10(23C) ]

S. 112 : Tax on long term capital gains -Non-residents – Concessional rate of tax — Long-term capital gains arising on sale of equity shares in Indian listed company to be taxed at 10.506 Per Cent., inclusive of surcharge and cess . [ S. 45 ]

S. 94 : Transaction in securities –loss on shares- Avoidance of tax by certain transactions in (Purchase and sale of bonds) –Transaction was not in the course of business hence provision of S.94(1) can not be applied [ S. 94(4) ]

S. 93 : Transactions resulting in transfer – Non-residents -Capital gains- For invoking S.93 to tax a resident, there should be transfer of assets by a resident to non-resident, and not where a non-resident had transferred assets to a resident- DTAA- India – Mauritius [ S. 90, 201(1), 201(IA) , Art ,13(4) ]

S. 92C : Transfer pricing – Arm’s length price -Selection of comparables — Various methods explained .

S.92C: Transfer pricing- Arm’s Length Price –Unless it is not shown that the selection of TNMM as the Most Appropriate Method is perverse, the same cannot be challenged.

S.92B: Transfer pricing – International transaction – Termination of option rights under an agreement can be treated as a “deemed international transaction”- Transfer pricing provision was held to be applicable and addition was held to be justified . Transfer of its unexercised call option right to nominate is held to be liable to capital gain tax . [ S. 2(47),92C ,92F]