S. 92C : Transfer pricing-Arm’s length price-Arm’s Length Price-Most Appropriate Method-Assembling goods partly purchased from its associated enterprise and partly developed by its own vendor-Resale Price Method adopted is not appropriate-Transactional Net Margin Method, Appropriate. [S. 144C]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Transfer pricing adjustment to be restricted to International Transactions rather than entity level transactions. [S. 92(1)]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method Or Cost-Plus Method-Directed to follow Cost Plus Method. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Comparables-Exclusion of companies on ground of revenue filter, non-availability of segmental data, functional dissimilarities-Held to be proper-Working capital adjustment on actual basis-allowable-Disallowance of interest would increase profits and gains derived from eligible-The addition relating to transfer pricing adjustment was not eligible for deduction under section 10A of the Act, in view of the bar provided in the proviso to section 92C(4) of the Act. [S. 10A, 92C(4)]

S. 90 : Double taxation relief-Foreign tax credit-Tax paid in USA, Japan and Germany-Credit available on all taxes paid in these countries-Tax paid in Korea-Limited to taxes payable on doubly taxes in India-Tax paid in Taiwan-No double taxation avoidance agreement with Taiwan-Foreign tax credit computed based on rate of tax applicable in India or Taiwan, whichever is less, on doubly taxable income-DTAA-India-USA-Japan-Germany-Korea. [S. 91, Art. 25, 23(2), 23(2), 23]

S. 80P : Co-operative societies-Banking facilities to members-Income attributable to carrying on business of banking-Deduction allowable. [S. 80P(2)(a), 80P(2)(a)(iii), 80P(2)(a)(vi)]

S. 80IC : Special category States-Manufacturing unit-Substantial expansion beyond five years-Entitle to exemption.

S. 80IB(10) : Housing projects-Completion Certificate-Completion Certified by Architects, planners and engineers-Delay in issue of completion certificate by local authority-Entitle to deduction-Allotment of residential members of same family-Disallowable proportionately. [S. 80IB(10)(f)]

S. 72 : Carry forward and set off of business losses-If return for which loss was claimed on due date the loss is allowed to carryforward and set off. [S.139 (1)]

S. 69 : Unexplained investments-Post dated cheque-No evidence to show that there was transfer of money-Addition is held to be not valid.