S. 92C : Transfer pricing – Arm’s length price – Comparables — Company Having Less Than 75 Per Cent. of its revenue from Information Technology Services to be excluded – Company engaged in provision of routine software development services

S. 92C : Transfer pricing – Arm’s length price – Net Margin Method —Companies having different functional profile — Companies for which segmental details not available are to be excluded – Profit margin at entity level could not be taken -Working capital adjustment to be given effect -Communication charges should be excluded both from export turnover and total turnover [ S.10A ]

S. 92C : Transfer pricing – Arm’s length price Comparables — Company having huge brand value and extraordinary events of to be excluded.-Computation of working capital level and consequent adjustment on account of working capital remanded to Transfer Pricing Officer for fresh consideration- Gains arising from fluctuation of foreign exchange having nexus with international transactions — to be treated as operating income and taken into consideration.

S. 92C : Transfer pricing – Arm’s length price – Adjustment not entry level transactions – Net margin method – Not opted for foreign exchange gain or loss is part of operating revenue or loss .

S. 92C : Transfer pricing – Arm’s length price – Comparables —Company which is a giant risk taking company and engaged in development and sale of software products is not Comparable —Foreign exchange fluctuation gain or loss is to be considered for transfer pricing analysis if it is in respect of current year’s turnover .

S. 92C : Transfer pricing – Arm’s length price -Interest on debentures —Equity and not debt — Deduction allowable — Matter remanded [ S.92CA ]

S. 90 :Double taxation relief – Tax credit – Law firm- Independent Personal Services applies only to individuals — Tax Credit Allowed – The legal fees paid to a partnership firm of lawyers can indeed subjected to levy of tax under article 12 as exclusion clause under article 12(4) does not get triggered for payments to persons other than individuals , and the provisions of article 14 are required to be read in harmony with the provisions of article – DTAA -India -Japan [ Art , 12, 14 , 23 (2)]

S. 80P : Co-operative societies – Entity Registered Under Karnataka Souharda Sahakari Act, 1997 — Co-Operative Society eligible for deduction [ S. 2(19), 80P(2)(a)(i) ]

S. 80P : Co-operative societies -Carrying on business of banking or providing credit facilities to its members —Matter remanded [ S.80P(2) ]

S. 80IA :Industrial undertakings – Infrastructure development – Amount received under agreement with Tamil Nadu Water Supply and Drainage Board for maintaining infrastructure facility — Eligible for deduction- Disallowance u/s 14A cannot exceed exempt income [ S.14A , 80IA(4) , R.8D ]