S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-Comparable-Employee cost filter-Different business model cannot be accepted as comparable-Extrodinary event of amlgamation cannot be accepted as comparable-Company engged in KPO services cannot be accepted as comparable. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Foreign AE can be taken as a tested party for purpose of establishing ALP of assessee.[S.92E, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-TNMM-CUP method-TNMM method is considered as most appropriate method-Order of Tribunal is affirmed-No substantial question of law.[S.260A, R.10B(2)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-AMP expenses-Bright Line Test (BLT) could not be applied for benchmarking AMP expenses-No substantial question of law.[S. 92B, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivable-Credit agreed between parties was 30 days-Extra credit allowed could be considered as an independent international transaction and same be compared with internal CUP being average cost of total funds available to assessee-SLP of revenue is dismissed due to low tax effect-Question of law is kept open. [Art.136]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Generation of power-Interest on Bonds issued by Grid Corporation in lieu of unpaid energy bills-Eligible for deduction-Order of High Court affirmed-SLP of Revenue is dismissed. [S. 80IA (iv)(a),80IB, 80IC, Art. 136]

S. 69C : Unexplained expenditure-Bogus purchases-Order of Tribunal restricting 8 % of purchase is affirmed. [S.260A]

S. 69C : Unexplained expenditure-Bogus purchases-Statement of director-No independent enquiry was made-Deletion of addition by the Tribunal is affirmed-No substantial question of law. [S. 132, 143(3), 260A]

S. 68 : Cash credits-Accomodatio entries-Sub broker-Applying the peak credit principle on estimate of 2 per cent as brokerage in respect of cash deposits, which ever is higher-Order of Tribunal is affirmed.[S. 260A]

S. 68 : Cash credits-Shares to promoters at premium-Capital or revenue-Income from other sources-Share premium cannot be assessed as revenue receipt even if assessee had breached provisions of section 78(2) of Companies Act, 1956, it would be penalised by provisions of Companies Act and breach would never turn share premium amount received into a revenue receipt-Share premium cannot be assessed as income from other sources. [S.56,260A, Companies Act, 1956, S 78(2)]