S. 143(1)(a) : Assessment-Intimation-Adjustment to the total income returned for the AY. 2017-18-Assessing Officer of CPC made an adjustment denying the credit for the TDS even though appearing in Form 26AS-No notice was issued to the assessee before making such adjustment. The CIT (Appeals) confirmed the Assessing Officer’s action for not granting TDS credit merely on the ground that the corresponding income has not been shown by the appellant in the return of income.[Form. 26AS]

S. 143(1)(a) : Assessment-Intimation-Co-operative society-Adjustment is not valid. [S. 80AC, 80P, 139(1)]

S. 115JB : Company-Book profit-Fuel and fixed cost adjustments made to power prices consequent to orders of regulatory commission-Liability ascertained-Expenditure deductible in computing book profit.[S. 37, 145]

S. 115JB : Company-Book profit –Insurance business-Assessee Not preparing financial statements as required under Companies Act-Minimum alternate tax not applicable. [S.44, Sch. I]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-The benchmarking has to be done based on the prevailing market rate which a normal bank would lend money with the minimum risk. Since the assessee has already mitigated the risk by investing in the fully convertible debentures when the risk is already mitigated one more time, the same risk element cannot be considered for bench marking on the interest payment also. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Application of turnover filter-Higher threshold limit of INR 200 crores-Excluded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on delayed receivables, credit period on invoices-interest on overdue export proceeds not charged from associated and non-associated enterprise-independent third parties on the similar transaction with a similar credit period of similar goods no interest charged-transfer pricing officer deleted adjustment. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Adjustment on account of interest paid on fully convertible debentures. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-ALP on combined transaction basis. ALP on combined transaction basis. [R.10A(d)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Companies with higher turnover to be excluded-Organisation for Economic Co-Operation and Development guidelines to be followed-Working capital adjustment to be allowed.[S.92CA]