S. 92C : Transfer pricing-Arm’s length price-TNM method-Cost plus method-TNM was directed to be applied-Beneficiary of AMP expenses or promotion of brand, said transfer pricing adjustment was to be deleted-Adjustment of royalty-Directed to be deleted.
S. 92C : Transfer pricing-Arm’s length price-Profit Split Method Royalty and AMP expenses-Required to be shown separately-Matter remanded.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally similarity-Safe to exclude it from final list of comparables to assessee who had been following fixed price project model-turnover filter of Rs. 1 crore, companies having turnover of more than Rs. 200 crores have to be excluded.
S. 92C : Transfer pricing-Arm’s length price-Foreign exchange fluctuation gain/loss be treated as an operating income / expenses-Comparable-Rejection of comparable was held to be not valid-Failure to provide annual report-Rejection of comparable was held to be valid-Customers whose segmental information was not available. could not be accepted as valid comparable-a comparable company engaged in purchase and sale of products could not be accepted as valid comparable-TP adjustment, if any, has to be restricted to international transactions of assessee with its Associated Enterprises only. [S. 92A]
S. 92C : Transfer pricing-Arm’s length price-Resale method-Trading in India-Matter remanded.
S. 92C : Transfer pricing-Arm’s length price-Order passed without giving any finding-Matter remanded. [S. 254(1)]
S. 92C : Transfer pricing-Arm’s length price-Interest free loan to Associated enterprises-Libor rate is to be applied-Corporate guarantee-Guarantee commission/fee to be charged at 0.5 per cent. [S. 92B]
S. 80IC : Special category States-Substantial expansion-entitle to deduction. [S. 80IC(8)(ix)]
S. 73A : Carry forward and set off of losses by specified business-Loss can be set-off another unit which was not eligible for deduction.
S. 73 : Losses in speculation business-Purchase and sale of securities-Loss on account of its clients-Loss cannot be treated as speculative in nature. [S. 28(i)]