S. 115JB : Book profit-Disallowance made under section 14A cannot be subject matter of disallowances while determining book profit. [S. 14A, R.8D]

S. 92C : Transfer pricing-Arm’s length price-Notional interest on interest free loan-Rate of LIBOR plus 2 per cent is held to be justified.

S. 92C : Transfer pricing-Arm’s length price-Re sale without any further value addition-Resale Price Method (RPM) is most appropriate method for determining ALP of said international transactions.

S. 92C : Transfer pricing-Arm’s length price-Advance for allotment of shares-Notional interest-No addition could be made.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Software development-Software education- Computer related activities like maintenance of website for its clients and creation of multimedia presentation-Product companies-Functionally not comparable-High turnover filter-Directed to be excluded.

S. 92C : Transfer pricing-Arm’s length price-AMP expenses-AE has not carried out any function in India-No international transaction in form of any agreement or arrangement on AMP expenditure incurred by assessee-Addition is held to be not justified. [S.92B]

S. 92C : Transfer pricing-Arm’s length price-Purchase product from AE and reseing to unrelated party-Resale price method (RPM) method was to be applied for benchmarking international transaction undertaken by assessee-Subvention payments by AE to reimburse part of operating expenses, said subvention amount received by assessee was operating in nature and was to be included as operating income-Promotion of Drug-Reimbursement of expenses-No transaction or international transaction could be said to be involved between assessee and its AE. [S.92B]

S. 92C : Transfer pricing-Arm’s length price-Notional interest-Interest on loan at LIBOR + 200 bps is held to be appropriate. [S. 92B]

S. 90 : Double taxation relief-Foreign tax credit-FTC paid subsequent to filing of return was to be allowed.-DTAA-India-USA. [S. 9(1)(i), ITR 128, Art. 25]

S. 80JJAA : Employment of new workmen-Persons working in software industry could be said to be workmen who render technical services and not services in the nature of supervisory or management character-Electronic design automation (FDA) software license First year of employment-Employees had worked for more than 300 days during relevant assessment years.