S. 132(4) : Search and seizure – Statement on oath-Undisclosed investment-Retraction of statement-Opportunity of cross-examination was not given – Merely on the basis of statement addition is not justified. [S. 69, 132, 260A]

S. 127 : Power to transfer cases -Kolkata to Delhi – Opportunity of hearing was given – Transfer for purposes of Co-Ordinated and detailed Investigation -Order of transfer was valid. [S. 127 (2), 132, 133A, Art. 226]

S. 127 : Power to transfer cases -Kolkata to Delhi -Natural justice – Failure to give an opportunity -Order was set aside.[S. 127(2), 132, 133A, Art, 226]

S. 127 : Power to transfer cases -Kolkata to Delhi – Search and seizure -Survey – Opportunity of hearing was given – Transfer for purposes of Co-Ordinated and detailed Investigation -Order of transfer was valid- The assessee has no right to be assessed under the Income-tax Act, 1961 in a particular area or locality- An order of transfer is purely in the nature of an administrative order passed for consideration of convenience of the Department and no possible prejudice can be involved when the cases have been transferred [S. 127 (2), 132, 133A Art.226]

S. 127 : Power to transfer cases -SLP dismissed – Observations of High Court to have no reflection on merits.[S. 127(2), 132, 133A Art. 136, 226]

S. 92C : Transfer pricing-Arm’s length price -Adjustment on account of interest-free loans-Libor +2 Per Cent.-Corporate guarantee-Write-off of loss on account of investment in equity shares in subsidiary -Book profits -Provision for doubtful debts -No question of law -Order of High Court affirmed -SLP of Revenue is dismissed. [S. 92B, 115JB, Art. 136]

S. 92C : Transfer pricing -Arm’s length price -Support services -Cost plus model -Commission based model- Comparable –Question of fact. [Art. 136, 226]

S. 92C : Transfer pricing -Arm’s length price – Reasoned order based on cogent reasons-Order of High Court affirmed -Question of law left open. [S. 136, 260A]

S. 80IB : Industrial undertakings – derived from – Profits from Duty Entitlement Passbook Scheme and Duty Drawback claims- Not income “Derived From” Industrial Undertaking-Not eligible for deduction. [28(iiib), 28(iiic), Art, 136]

S. 80IA : Industrial undertakings-Telecommunication Services Change in shareholding-Block of ten consecutive years-Losses which have lapsed cannot be taken into account for purposes profits of undertaking. [S. 79, 80IA(5)]