S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on loan given to Associated Enterprise-Interest in terms of safe harbour rules acceptable-Arm’s Length price adjustment is to be made accordingly. [S.92B, 92CA, R. 10TD(2A)(5)]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Interest on trade receivables-Interest rate on similar foreign currency receivables and advances as Libor + 200 Points-Adjustment on account of interest on trade receivables unwarranted-Payment for global and regional management-Restored to Assessing Officer for fresh factual verification.[S.92C]

S. 80P : Co-operative societies-A State-level non-banking Co-Operative credit Society-Did not fall under exception under Section 80P(4)-Nominal and associate members-Members to include nominal and associate members-Entitled to deduction-employees could not be considered attributable to business of assessee-Not entitled to deduction-to be treated as income from other sources-Interest from loans extended to employees of assessee-Interest from investments-Necessary relief to be granted under Section 57 in respect of cost of funds and proportionate administrative and other expenses in accordance with law-Issue restored to Assessing Officer for de novo consideration-Guarantee Commissions-Cannot be considered as Levy or ccess-Issue remanded to Assessing Officer to carry out necessary verification based on agreement entered into by assessee with Government and to analyse if payment of guarantee commission is an admissible deduction-Business Loss-Matter remanded–E-Stamping Income-Income earned from E-stamping cannot be considered for purpose of deduction-Assessing Officer is directed to consider alternate claim of assessee in accordance with Law. [S. 37(1), 43B, 56, 57, 80P(2)(a)(i), 80P(2)(d)(4), Banking Regulation Act, 1949, 5(c), Karnataka Co-Operative Societies Act, 1959, S.2(F)]

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Market value of goods-Generating power from windmills for captive consumption-Initial year-Electricity purchased from Tamil Nadu Electricity Board and other Private power producers is proper.

S. 80G : Donation-Deductions to be restricted to 10 Per Cent. of gross total income-Entitled to deduction in respect of donations to institute registered under section 80G(2)(a)(iiif)-Claim shown separately in computation of total income-No infirmity in Commissioner (Appeals) directing Assessing Officer to verify claim and grant it-Not claimed benefit of sections 11 and 12 of the Act, there was no question of granting the benefit of carrying forward the deficit of this year to the next year. [S.11, 12, 80G(2)(a)(iiif), 80GGA]

S. 69C : Unexplained expenditure-Bogus purchases-Trading in Iron and steel scrap-Sales not disputed-Regular transaction with supplier-Ledger confirmation of supplier-Order of CIT(A) deleting the addition is affirmed. [S. 143(3)]

S. 69C : Unexplained expenditure-Income from undisclosed Sources-Survey-Accommodation entries-Bogus purchases-Addition to the extent of 12.5 Per Cent is affirmed-Reassessment is affirmed. [S.133(6) 139, 147, 148]

S. 69C : Unexplained expenditure-Bogus purchases-Sales accepted-Disallowance of purchases are deleted.[S. 37(1)]

S. 68 : Cash credits-Cash Deposits-Demonetisation period-Cash sales explained-Basis of cash sales made in earlier financial year can not be adopted as a parameter for accepting cash sales made during year.

S. 61 : Revocable transfer of assets-Trust-Association Of Persons-Stressed Assets Of Banks And Financial Institutions Acquired By ARCIL by setting up Trusts and formulating schemes-Trust is not an Association of persons-No discretion is given to trustee to decide allocation of income every year, nor right given to beneficiary to exercise option to receive income or not-Income liable to be assessed in hands of beneficiaries-Respective shares known since inception-Assessee could not be considered as an indeterminate trust. [S. 63, Indian Trusts Act, 1882, S. 7, 9, Securitisation And Reconstruction Of Financial Assets And Enforcement Of Security Interest Act, 2002]