S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-TNMM-CUP method-Payment of royalty-Determnetal to the interest of both assessee and Revenue-Addition was delted. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Sale of software-Comparables-Segmental information was not available-Cannot be accepted as comparable.

S. 90 : Double taxation relief-Taxes deemed to have been payable-Eligible to tax credit- Tax payable -Income by way of dividend, received from its subsidiary in Thailand-Income deemed to accrue or arise in India-DTAA-India-Thailand. [S. 9(1)(i),9(1)(iv), Art. 23(3), 23(5)]

S. 80P : Co-operative societies-Deduction-Notice is issued in SLP filed by the Revenue. [S. 80P(2)(a)(i),80P(4), Regional Rural Development Act, 1976, S. 22]

S. 80IC : Special category States-Industraial undertaking-Initial assessment year-Substantial expansion within period of ten years-Eligible deduction-Year of substantial expansion would be initial year for start of 100 Per Cent. deduction. [S. 80IC(8)(ix)]

S. 80IA : Industrial undertakings-Infrastructure development-Survey-Incumbent on part of Assessing Officer to grant deduction once the Central Government has granted approval. [S. 80IA(4)(iii), 133A, 153A]

S. 69C : Unexplained expenditure-Bogus purchases-No discrepancy between purchases shown and sales declared-Only gross profit ratio can be applied-Order of Tribunal is affirmed. [S.260A]

S .69C : Unexplained expenditure-Survey-Bogus purchases-Statement retracted-Deletion of addition by the Tribunal is affirmed. [S.131, 133A 260A]

S. 69B : Amounts of investments not fully disclosed in books of account-Sauda Chithhi-Dumb documents-Incriminating documents-Sale of land-Land was not transferred-Deletion of addition by the Tribunal is affirmed. [S. 45, 260A]

S. 69A : Unexplained money-Seizure of gold-Distinctive identification numbers on challans-Deletion of addition by the Tribunal is affirmed. [S. 260A]