S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivable-Credit agreed between parties was 30 days-Extra credit allowed could be considered as an independent international transaction and same be compared with internal CUP being average cost of total funds available to assessee-SLP of revenue is dismissed due to low tax effect-Question of law is kept open. [Art.136]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Generation of power-Interest on Bonds issued by Grid Corporation in lieu of unpaid energy bills-Eligible for deduction-Order of High Court affirmed-SLP of Revenue is dismissed. [S. 80IA (iv)(a),80IB, 80IC, Art. 136]

S. 69C : Unexplained expenditure-Bogus purchases-Order of Tribunal restricting 8 % of purchase is affirmed. [S.260A]

S. 69C : Unexplained expenditure-Bogus purchases-Statement of director-No independent enquiry was made-Deletion of addition by the Tribunal is affirmed-No substantial question of law. [S. 132, 143(3), 260A]

S. 68 : Cash credits-Accomodatio entries-Sub broker-Applying the peak credit principle on estimate of 2 per cent as brokerage in respect of cash deposits, which ever is higher-Order of Tribunal is affirmed.[S. 260A]

S. 68 : Cash credits-Shares to promoters at premium-Capital or revenue-Income from other sources-Share premium cannot be assessed as revenue receipt even if assessee had breached provisions of section 78(2) of Companies Act, 1956, it would be penalised by provisions of Companies Act and breach would never turn share premium amount received into a revenue receipt-Share premium cannot be assessed as income from other sources. [S.56,260A, Companies Act, 1956, S 78(2)]

S. 68 : Cash credits-Capital gains-Long term capital gains on sale of shares-Demat account for more than 12 months-Entry operator-Report from Investigation wing-Accomodation entries-Sold through stock exchange after payment of security transactions tax-Denial of opportunity of cross examination-Entitle to exemption-Tribunal is justified in deleting the addition-Delay in filing SLP is not condoned-SLP of Revenue is dismissed. [S. 10(38), 45, 69, 133A, Art. 136]

S. 68 : Cash credits-Capital gains-Long term capital gains on sale of shares-Demat account for more than 12 months-Entry operator-Sold through stock exchange after payment of security transactions tax-Denial of opportunity of cross examination-Entitle to exemption-Tribunal is justified in deleting the addition-SLP of Revenue is dismissed. [S. 10(38), 45, 69, 133A, Art. 136]

S. 68 : Cash credits-Capital gains-Long term capital gains on sale of shares-Demat account for more than 12 months-Entry operator-Sold through stock exchange after payment of security transactions tax-Denial of opportunity of cross examination-Entitle to exemption-Tribunal is justified in deleting the addition-SLP of Revenue is dismissed. [S. 10(38), 45, Art. 136]

S. 56 : Income from other sources-DCF method-Valuation report by a merchant banker-Assessing Officer is not empowered to value the shares on net valuation method-Directed to exercise of valuation afresh in accordance with DCF method.[S. 56(2)(viib), 56(2)(viic), 260A, R.11UA(2)]