S. 92C : Transfer pricing-Arm’s length price-Comprables-Exclusion of company from the comparable is set aside-Amount of export incentives is liable to be considered as part of operating revenue-Transfer pricing adjustment is to be restricted only to the extent of international transactions-TPO is directed to grant working capital adjustment as per the methodology suggested by DRP. [S. 144C]
S. 92C : Transfer pricing-Arm’s length price-CUP method is not the most appropriate method in the facts of the case-Assessing Officer is directed to determine ALP under the TNMM but restricting the amount of adjustment only to the International Transactions. [R. 10B]
S. 92C : Transfer pricing-Arm’s length price-Cup method-Rate at which the distribution company sells the electricity to the customers has to be adopted the transactions relating to transfer of electricity to other units-Purchase made from AE are at arm’s length price and non AE transactions are considered under CUP method.
S. 92C : Transfer pricing-Arm’s length price-Royalty-Net margin is higher than the margin of the comparables, addition was deleted-It is not obligatory for the assessee to demonstrate as to whether or not the international transaction has resulted into economic benefit. [S. 92BF(ii)]
S. 90 : Double taxation relief-Tax credit-Assessing Officer will examine the provisions of the respective tax treaty and compute thee admissible tax credit separately for each jurisdiction-Matter remanded. [S. 37(1), 90(3), 280Z, A297(2)(k), General Clauses Act, S 24]
S. 80P : Co-operative societies-Interest and dividend income-Directed the Assessing Officer to consider de novo and to verify whether assessee had deducted tax at source on interest payment to non-members exceeding Rs. 10,000 per annum. [S. 80P(2)(a)(i), 80P(4)]
S. 80P : Co-operative societies-Souhardasahakari Registered Under Karnataka Souharda Co-Operative Act, 1997-Eligible For Deduction [S. 2(19), 80P(2)(a)(i)]
S. 80P : Co-operative societies-Souhardasahakari Registered Under Karnataka Souharda Co-Operative Act, 1997-Eligible For Deduction [S. 2(19), 80P(2)(a)(i)]
S. 80P : Co-operative societies-Return filed in the status of firm-Rectification application moved to change the status as an AOP and for allowing the claim u/s. 80P of the Act-Conditions of section 80A(5) is not satisfied-Denial of deduction is valid. [S. 80A(5), 80P(2)(a)(i), 143(1), 154]
S. 80IC : Special category States-Estimate of GP at 40 percent of total turnover as against GP disclosed at 57-01 percent-Taxed difference of 17.01 as income from other sources and denied the exemption-Order of CIT(A) is affirmed. [S. 56, 145 (3)]