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 – 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 ]
S. 80G : Donation -Expenditure on corporate social responsibility — Denial of deduction is held to be not justified – CIT (A ) has the power to entertain the claim though not made in the return or revised return [ S.254 (1) ]
S.69C:Unexplained expenditure — Personal household expenses — Joint family — Expenses reduced by 50 Per Cent.
S.68: Cash credits – Loan received through proper banking channel — Addition is held to be not justified .