S. 92C : Transfer pricing-Arm’s length price-Adjustment of filters, etc-No substantial question of law. [S. 92CA, 260A]

S. 92B : Transfer pricing-International transaction-Corporate guarantee-Substantial question of law admitted by High Court. [S. 92C, 260A]

S. 70 : Set off of loss-One source against income from another source-Same head of income-Loss on sale of shares and units of mutual funds on which STT was paid-Set-off of loss against sale of land-Loss cannot be set off against long term capital gains arising from sale of land. [S. 10(38), 45, 48, 55, 70(3)]

S. 68 : Cash credits-Unsecured loans-Identity of creditors and genuineness of transitions and creditworthiness established-Deletion of addition is held to be justified.

S. 68 : Cash credits-Share capital and share premium-All share holders are duly cross verified-Deletion of addition is held to be justified.

S. 45 : Capital gains-Shares and securities as investment-Assessable as capital gains and not as business income-Interest free funds available was more than gross investment-No disallowance can be made. [S. 14A, 28(i), R.8D]

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Agricultural land-Seller insisting cash payment-Affidavit by assessee-Disallowance is held to be not justified.

S. 37(1) : Business expenditure-Software licence expenses-Expenditure for software running system-Allowable as revenue expenditure.

S. 37(1) : Business expenditure-Research and Development (R&D) expenses-Not produced documentary evidence-Matter remanded. [S. 35 (2AB)]

S. 36(1)(iii) : Interest on borrowed capital-Working capital-Foreign exchange for working capital-Allowable as deduction.