“Section 4(2)(b)”

A retracted statement made during a search under section 132(4) carries no weight and is rejected, especially when the genuineness of purchases is disproved.

An appellate authority can admit additional legal grounds for the first time, even if not raised earlier, provided these grounds are purely legal, go to the root of the matter, and the relevant facts for their adjudication are already on record.

The Centralized Processing Centre (CPC) can deny deductions claimed under Chapter VI-A, such as Section 80P, during the processing of a return under Section 143(1) if conditions for claiming such deductions, including filing the return by the due date as per Section 80AC, are not met.

When the valuation of closing stock is adjusted to include CENVAT or Modvat credit under Section 145A, a corresponding adjustment must also be made to the opening stock.

When the Assessing Officer revalues the closing stock, the opening stock must also be revalued on the same basis to ensure consistency in the method of accounting and proper computation of business income.

An Indian company that exercises control and supervision over a seconded employee and bears the salary cost is an economic employer. Such a company is not liable to withhold tax on the reimbursement of salary to the overseas company, thereby avoiding disallowance under Section 40(a)(i).

For comparability analysis in transfer pricing, giant companies with significantly higher turnover and brand value cannot be compared with small-sized companies, and such companies should be excluded from the comparable set.

Receipts do not constitute 'fees for technical services' under Section 9(1)(vii) of the Income Tax Act and Article 12(4)(b) of a Double Taxation Avoidance Agreement (DTAA), specifically when interpreting the 'make available' clause.