S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Turnover filter-Turnover filter up to ten times can be applied-Matter restored to the file of Assessing Officer. [S.92B]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Advertisement, marketing and promotion expenses-Burden is on revenue. [S.92CA(3)]

S. 68 : Cash credits-Income from undisclosed sources-Cash deposits in Bank Account-Withdrawal from one account and deposited in another bank account-Addition is not justified-Payment in cash of stamp duty for purchase of property-Addition is not justified.

S. 68 : Cash credits-Bogus purchases-Providing accommodation entries by way of circular transactions of bogus purchases and sales-Addition cannot be made as cash credits-Only commission income can be assessed as income.

S. 50C : Capital gains-Full value of consideration-Stamp valuation Sale of property within three and half months of purchase-Assessing Officer ought to have referred valuation to District Valuation Officer-Order set aside and issue remanded with the direction to call valuation report. [S. 45-48(1), 50C(2)

S. 45 : Capital gains-Long-term capital gains-Survey-Papers found in the premises of advocate-Satakat bearing name and details of assessee-No corroborative evidence to support material

S. 40(a)(i) : Amounts not deductible-Deduction at source-No disallowance can be made for short deduction of tax at source.

S. 37(1) : Business expenditure-Self-generated bills and vouchers Not Verifiable-Material purchase expenses restricted to 50 Per Cent.-Other expenses directed to be allowed. [S.44AD]

S. 28(i) : Business loss-Foreign exchange rate fluctuation-Allowable as deduction.

S. 28(i) : Business income-Income from house property-Business expenditure-Renting of parking spaces, table spaces and games collection-Renting activity against which maintenance recovered from tenants to be considered under business and balance to be disallowed as pertaining to income from house property-Matter remanded. [S. 22, 24, 37(1)]