S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Transactional Net Margin Method-Purchase of raw materials-Adjustment upheld-Adjustments to profit margin by transactional net margin method rejected-Defective material supply-Abnormal cost included in actual cost-further adjustment of cost by re categorisation as income not per principle of transfer pricing-Transfer pricing adjustment deleted.[S.92CA]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Functionally different-Higher turnover-Excluded from final list-Appeal-Appeal is filed with in 60 days from the date of judgement High Court-No delay in filing of appeal. [S.92CA, 254(1)]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-Corporate guarantee-Charging of guarantee fee of 0.8 Per Cent is justified-Further adjustment is not valid.[S.92CA]
S. 80P : Co-operative societies-Delay is condoned-Regular, nominal and associate members-Issue is remitted to Commissioner (Appeals).[S.80P(2)(a)(i), 143(3)]
S. 80IC : Special category States-Gross profit from trade purchases with subsidiary not different to that from third parties-No evidence of shifting expenses to subsidiary.
S. 80IC : Special category States-Entire production sold to firm-Not disputing the sale price-No mistakes in books of account-No diversion of profit to firm-Denial of exemption is not justified. [S. 80IC(3)(ii), 80IE]
S. 80IB(10) : Housing projects-Claiming deduction in revised return-Matter remanded for reconsideration. [S. 139(1)]
S. 80IB : Industrial undertakings-Production of aluminium products-Allowable deduction.
S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Captive power plant-Supply of power to own unit-Sale of small portion to State grid corporation-Rate to be adopted-Market value-Rate at which State Electricity Board supplies to industrial consumers. [S. 80IA(8)]
S. 80HHC : Export-Turnover in excess of Rs. 10 Crores-In Terms Retrospective amendment-Struck down by High Court and affirmed by Supreme Court-Substantive amendment with retrospective operation-Effective only from date of amendment.[S.80HHC(3)]