S. 147 : Reassessment–With in four years-Failure to deduct tax at source–Merely on the doubt about applicability of tax deducted at source, reassessment is held to be not valid. [S. 40(a)(ia), 148]

S. 124 : Jurisdiction of Assessing Officer-Jurisdiction of AO cannot be called in question by assessee after expiry of one month from date of which he was served with notice u/s. 142(1) or after completion of assessment, which was to be earlier. [S. 142(1)]

S. 92CA : Reference to transfer pricing officer–Additional grounds-Jurisdiction-Joint Commissioner–Joint Commissioner of Income-tax-Addl. CIT can act TPO. [S. 2(28C), 92CA(7), 116(cc), 116cca)]

S. 92C : Transfer pricing–Arm’s length price–No transfer pricing adjustment can be made on transactions with the non-AEs– Matter remanded.

S. 92C : Transfer pricing–Arm’s length price–LIBOR instead of LIBOR + credit spread on account of the risk profile of the borrower.

S. 92C : Transfer pricing–Arm’s length price–Loan to AE-Interest should be charged at LIBOR+200 bps.

S. 92C : Transfer pricing–Arm’s length price–Comparable-Directed the TPO to compute margins by taking foreign exchange fluctuations gains/loss as part of operating income both in the case of the assessee and comparable companies.

S. 92C : Transfer pricing–Arm’s length price–Additional evidence was produced–Matter remanded. [S. 254(1)]

S. 92C : Transfer pricing–Arm’s length price–DRP was right in law in accepting the contention of assessee to grant custom duty adjustment, when the assessee has worked out the adjustment in its own hands while as per Rule 10B(1)(e)(iii), if any adjustment is to be made it should be made in the hands of comparable companies only.

S. 92C : transfer pricing–Arm’s length price–Professional fees-TNMM-CUP method–Matter remanded to the TPO.