S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Functionally different-Not comparable.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Payment of technical fees for services rendered-Neither Assessing Officer nor Transfer Pricing Officer nor Commissioner (Appeals) doubted actual Rendering or utility of services-Not open to Department to question actual rendering of services before Tribunal.-Most Appropriate Method-Transactional Net Margin Method-For immediately preceding and succeeding years payment of technical service fees accepted without Transfer Pricing adjustments-Rule of consistency is followed-Rejection is not justified. [S. 254(1)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Transactions with entity to be considered in consolidated way and not to be bifurcated according to calendar year in that contracting state-Rate applied in Mutual Agreement Procedure for transactions between assessee and United States associated enterprise for period April 2012 to December 2012 to transactions during January 2013 to March 2013.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Additional evidence-Resale method-Notional interest on advances-Matter remanded. [S.144C, 254]

S. 69C : Unexplained expenditure-Document found during search-Cash payment-Statement of manger retracted-Addition is deleted. [S. 132, 132 (4)]

S. 69C : Unexplained expenditure-Transactions through Banking Channels-Deletion of addition is affirmed.

S. 68 : Cash credits-Unsecured loans-Filed confirmations, copies of returns, bank statements-Burden discharged-Order of CIT(A) deleting the addition is affirmed.

S. 68 : Cash credits-Share capital and share premium-Proved source and also source of source-Addition is not justified. [S.133(6)]

S. 56 : Income from other sources-Receipt of shares of closely held company for inadequate consideration or without consideration-Amalgamation-Shares received by assessee-company on account of amalgamation for price lower than fair market value-Not within ambit of specific exclusions-Charge attracted-Matter of valuation remanded-Receipt of shares does not stipulate transfer of shares-Interpretation of taxing statutes-Specific charging provision-General provision will give way to specific Provision-Assessment-Protective or Precautionary addition permissible. [S. 2(IB), 2(14) 47(vi), 56 (2)(viia)]

S. 45 : Capital gains-Entity forming consortium with equal shares-Assessee transferring shares in consortium-Cost indeterminate Deleting addition-Order of CIT(A) deleting the addition is affirmed.