S. 92C : Transfer pricing-Arm’s length price-Comparable-Tested party-Cost Plus Method (CPM)-Audit of segmental accounts-Cannot be rejected on the ground that the Accounts of overseas entities were not audited.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Tested party-Cost Plus Method (CPM)-Audit of segmental accounts-Cannot be rejected on the ground that the Accounts of overseas entities were not audited.
S. 92C : Transfer pricing-Arm’s length price-Comparable-Matter remanded to the TPO-Turnover cap-Goodwill-Loss making companies-Size and Economies of Sale/High Risk Companies.
S. 92C : Transfer pricing-Arm’s length price-ITES services did not form a single composite transaction-Transactions cannot be aggregated-Extended credit period-Addition of notional interest is held to be not justified.
S. 92C : Transfer pricing-Arm’s length price-Loan and advance-Interest-CUP method-Reimbursement of expenses-No adjustment can be made-Corporate guarantee was extended by assessee as a shareholder activity-No adjustment can be made. [S. 92B]
S. 80P : Co-operative societies-Deposit from members-Assessing Officer passing the order, without verifying the licence to carryon banking business-Matter remanded to the Assessing Officer. [S. 80P(2)(a)(i)]
S. 69A : Unexplained investment-Jewellery-Weight of jewellery allowed as per instruction No 1916, dt. 11-5-1994 need not be explained-Addition cannot be made-Over and above the quantity of the jewellery has been explained, no addition can be made.
S. 68 : Cash credits-Share capital-Mere submission of name and address of creditor, income tax returns, balance sheet/statement of affairs of creditor and bank statement of creditor is not sufficient.
S. 68 : Cash credits-Cash deposited-Bank-Sale of Agricultural land-Gift-Failed to show the creditworthiness-Addition is held to be justified-Enhancement without giving an opportunity of hearing is held to be bad in law. [S. 251]
S. 64 : Clubbing of income-Spouse-Wife invested gifted amount in business of Futures and Options (F&O)-Loss incurred by wife is Liable to be clubbed in hands of assessee for the purpose of set off. [S. 64 (1)(iv)]
S. 56 : Income from other sources-Compensation from Tenant for not letting out two units without the consent-Assessable as income from other sources and not as income from house property. [S. 22, 23]