S. 92C : Transfer pricing-Arm’s Length Price—royalty for use of brand name— Adjustments held to be not justified.

S. 92C : Transfer pricing-Arm’s Length Price—AMP expenses incurred by MSIL could not be treated and categorized as international transaction- No adjustment can be made. [S. 92B]

S. 92C : Transfer Pricing—Arm’s length price—Purchases of cars by assessee from RNAIPL would not come within meaning of international transaction-Marketing expenses-No addition can be made. [S. 92B]

S. 92C : Transfer pricing—adjustment—financial advisory solutions in the field of investment banking division–TNMM method entry level- Effective representation was not made before TPO or CIT(A) –Matter remanded to the AO / TPO.

S. 92C : Transfer Pricing—Transport Segment-Import of raw materials and components-Import of finished goods-and Export of finished goods—Additional evidence was filed-Matter remanded.

S. 92C : Transfer pricing—Comparables—Functionally indifferent companies cannot be selected as good comparable-Asset management company cannot be compared with market support services.

S. 92C : Transfer pricing–Arm’s length price–Notional interest– Loan to AE–Estimate of interest at 11% was held to be not valid when the assessee had charged the interest at 8%-Rule of consistency is followed–Bench mark transaction-Cup method–Adjustment made was deleted–Ad hoc method cannot be applied. [S. 92CA] .

S. 69C : Unexplained expenditure-Bogus Purchases-Raw material-Survey-Letters were issued to the purchasers after five years of end of assessment year-purchasers are witness of department and did not turn of for cross examination- Inspectors report was not confronted to the assessee- Deletion of addition was held to be justified. [S. 133A, 143(3), 145]

S. 69 : Unexplained investment –Undisclosed income-Merely on the basis of AIR information and ITS data addition cannot be made. [S.131, 133(6), 143(3)]

S. 44BBB : Foreign companies-Civil construction-Turnkey power projects -Books of account maintained–Applicability of presumptive taxation cannot be thrust upon the assessee.[ S.44AA, 44AB, 44BBB,145 (3)]