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)]
S. 80ID : Hotels and convention centers in specified area-Transfer of a building previously used as a Hotel-Not eligible deduction. [S. 80ID(3)]
S. 80IB(8A) : Scientific research and development-Hybrid cotton seeds-Matter remanded. [S. 80IA]
S. 80IA : Industrial undertakings-Infrastructure development-Developer-cum-contractor-Eligible for exemption. [S. 80IA(4))(i)]
S. 69C : Unexplained expenditure-Bogus purchases-Ad-hoc addition-Only difference between gross profit rate on genuine purchases and gross profit rate on alleged hawala can be added-Once reassessment is held to be valid-Free to assess any other income. [S.147, 148]