S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on loans advanced to Associated enterprise uncontrolled price method-Adjustment is deleted-Loan advanced from own funds-Matter remanded to Assessing Officer for re adjudication-Corporate guarantees are International Transactions-Rate of fees to be determined on the basis of guarantee is obtained from a bank-One half Per Cent. considered appropriate on basis of average rates charged by banks. [S.92B]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Functionally different and without segmental data is to be excluded-Functionally similar to be included-Notional interest-Outstanding receivable-Factors responsible for delay to be analysed over last three or four Assessment years to determine benefit accruing to debtors–Working capital adjustment-Matter remanded-Deduction at source-Form 26AS-Matter remanded for re-examination. [S.92B S, Form No, 26A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Loans to two overseas subsidiaries-Domestic prime lending rate is inapplicable-Addition is deleted

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Transfer Pricing Officer is bound to follow one of prescribed methods-Addition is deleted-Selection of comparable-Matter remanded-Interest on refund-Entitle interest up to date of receipt of refund order.[S.92CA, 234D, 244A]

S. 90 :Double taxation relief-Capital gains-Tax resident of Singapore-Capital gains on sale of shares of Indian company-Denial of exemption is not justified-DTAA-India-Singapore [S.9(1)(i), Art. 13 (4)]

S. 90 :Double taxation relief-Non-Resident-Resident in Mauritius-Tax Residency certificate-Agreements executed in Mauritius-Entitle to exemption-DTAA-India-Mauritius-Circular No. 682 of 1994, Dated 30-3-1994(1994) 207 ITR 7 (St) Circular No. 789 Of 2000, Dated 13-4-2000(2000) 243 ITR 57 (St). [S.9(1)(i), 112 Art. 4, 13(4)]

S. 80P : Co-operative societies-Interest income on investments made with Co-Operative Banks-Entitle to deduction. [S.2(19), 80P(2)(d)] Co

S. 69A : Unexplained money-Cash deposit-Demonetisation period-Natural justice-Matter remanded to CIT(A) to explain the source of cash sales with required documents.[S. 44AD, 143(3), 144B, 250(6)]

S. 69A : Unexplained money-Delay of 89 days in filing of appeal-condoned-Unexplained investments-Not filed the return-Disputed sale consideration-Addition made on wrong assumption of facts-Addition is deleted-Income not exceeding the maximum amount-Provision of section. 249(4) cannot be invoked. [S.115BBE, 147 148, 154]

S. 69A : Unexplained money-Cash deposits in bank-Demonetisation-Petrol pump-Cash flow chart-Addition is deleted.