S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on delayed receivables-Selection of comparables-Exclusion of comparables by Tribunal on ground of functional dissimilarities-Order of Tribunal affirmed. [S.92B, 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Order of Tribunal affirmed.[S.260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Advertising, marketing and promotion expenditure-Applying the bright line test was sustainable-Pendency of SLP-Liberty given to revive the appeal if the department succeeds in its pending SLP.[S.260A

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Distributor purchasing goods from associated enterprises and reselling without any value addition-Gross profit is a determinative factor-Resale price method is most appropriate.[S. 144C, 260A]

S. 79 : Carry forward and set off losses-Change in share holdings-Companies which public are not substantially interested-Observations of Assessing Officer considering assessment for earlier year of no effect and not sustainable.[S. 260A]

S. 69C: Unexplained expenditure–reassessment–trader in diamonds-Information from Investigation wing-Bogus purchases-Commission agent –Bhanwarlal Jian-Books of account not rejected-Order of Tribunal estimating at six per cent is affirmed. [S. 132(4), 147, 148, 260A]

S. 56 : Income from other sources-Grants received by statutory corporation from Government for construction of housing for Police Department-Interest on deposit of such grant amounts in banks-Assessable as income from other sources-Interest paid not allowable as deduction. [S. 36(1)(iii)]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability-Capital or revenue-Pre-payment of deferred sales tax liability-Capital receipt.[S. 4, 260A]

S. 40A(3): Expenses or payments not deductible-Cash payments exceeding prescribed limits-Amendment with effect from 1-4-2009-Disallowance of payments exceeding specified limit to a single person on a single day-No evidence of separate payments made on a single day to assessee-Disallowance justified. [R.6DD]

S. 32: Depreciation-Intangible assets-Business and commercial brand equity are goodwill-Depreciation allowable. [S. 260A]