S. 92C : Transfer pricing-Arm’s length price-Reimbursement of expenses-Adjustment cannot be made-Comparable-Functional similarity-Providing a platform for sale of electronic products of multiple brands-Cannot be held to be comaparble-Manufacture and trading of consumer electronics, home appliances-Different financial year-Matter remanded. [S. 92B]

S. 92C : Transfer pricing-Brand value-Company having high brand value and turnover as compared to assessee-company could not be selected as comparable.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally dissimilarity and various other factors such as extraordinary performance etc. cannot be held to be comparable-Segments details are not available matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Threshold limit for application of RPT filter cannot be fixed as zero per cent-15% to 25%.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Captive routine software development service provider-A company operating in diversified markets, owning IPRs and brand value and focussing on R&D could not be comparable-Functionally different cannot be comparable-PLI should be worked by considering provision for doubtful debts as operating expenditure.

S. 92C : Transfer pricing-Arm’s length price-Rule 10B permits to aggregate comparable uncontrolled transactions for determining ALP, however, it does not permit to aggregate international transactions carried out by assessee to work out average price for purpose of comparison-Once comparable company becomes AE of assessee in year under consideration, then such company cannot be considered as comparable. [S. 92A(2), R.10B]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Segmental result not reliable-Product designing-Product company-Not comparable-Interest rate-Delay in recovery of sales consideration-No adjustment can be made.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Segmental result not reliable-Product designing-Product company-Not comparable-Interest rate-Delay in recovery of sales consideration-No adjustment can be made.

S. 80P : Co-operative societies-Credit Co-operative Bank-Agricultural loan-Matter remanded. [S. 80P(2)(a)(i)]

S. 80P : Co-operative societies-Credit co-operative banks-Loan disbursement-Narration in loan extracts in audit reports by itself may not be conclusive-Matter remanded. [S. 80P(2)(a)(i)]