S. 119 : Central Board of Direct Taxes-Instructions-Delay in filing of return-Application for condonation of delay was filed after 16 years-Delay was rejected-Writ petition was dismissed. [S. 119(2)(b), 139, Art. 226]

S. 115JB : Company-Book profit-Unabsorbed depreciation-Brought forward losses-Which evev is less as per books must be permitted. [S. 32]

S. 115AC : Capital gains-Bonds-Global Depository-Foreign currency-Transfer of Shares covered by scheme-Computation of capital gains to be made under provisions of scheme-Subsequent Amendment of provisions in Income-tax Act is not applicable.-Transaction not regarded as transfer-Capital gains-Transfer by way of conversion of bonds in to shares or debentures-Date of acquisition – Foreign currency bonds-Date of acquisition to be date of conversion of bonds into shares – Amendments in 2008 is not applicable – SLP is dismissed. [S. 2(42A) 47, 47(xa), 49(2A), Foreign Currency Convertible Bonds and ordinary Shares (Through Depository Receipt Mechanism) Scheme, 1993, Clause 7(4)]

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]