“Section 44(2)”

For income to be assessable under the head 'Income from House Property' as per Section 22 of the Income Tax Act, 1961, beneficial ownership or the right to enjoy the property is sufficient; legal ownership is not a mandatory prerequisite.

Foreign exchange fluctuation gains or losses are operational in nature and must be included in the computation of the operating margin for both the assessee and comparable companies when determining the Arm's Length Price.

The Mumbai Tribunal has held that the term 'process' in relation to royalty under Section 9(1)(vi) of the Income Tax Act is not defined and must be considered within the contemplation of the term, potentially impacting its application under DTAAs. This decision distinguished itself from the facts of other cases, including those involving broadcasting and advertising airtime.

High turnover serves as a valid criterion for excluding a company from the list of comparable companies when determining the Arm's Length Price (ALP) in transfer pricing adjustments.

A provision made for Unclaimed Prior Revenue (UPR) is not an item to be added back to book profit under Explanation 1 to section 115JB(2) of the Income Tax Act, 1961.

To determine if an expenditure is capital or revenue, one must consider the nature of the business, the expenditure, the right acquired, and their inter-relation. The concept of 'enduring benefit' is descriptive and relative, not synonymous with perpetual.

An assessment order is 'erroneous' under Section 263 only if it is contrary to law or based on a mistaken application of legal principles. Revision orders are unsustainable if they are not founded on such an error in the original assessment.

The Assessing Officer's power to make adjustments is restricted, particularly concerning actuarial valuations, and this power is bound by principles laid down by the Supreme Court.