S. 139 : Return of income-Delay in filing of return-Dedcution of tax at source-Refund-Genuine hardship-COVID-19-Court held that genuine hardship and it should receive a liberal construction-Court held that this being a case of genuine hardship caused to assessee, delay-Order rejecting condonation of delay application is quashed. [S.54, 119(2)(b), Art. 226]

S. 132B : Application of seized or requisitioned assets-Cash seized-Shall release-Assessing Officer is directed to decide application of assessee and if nature and source of cash seized was duly explained, such refundable amount would attract liability of interest under section 132B(4) read with Matter remanded. [S. 132, 132(4), Art. 226]

S. 119 : Central Board of Direct Taxes-Charitable Trust-Delay in filing Form No 10B-Delay of 1257 days-Oversght by the Chartered Accountant-Human error lacking any malafide intention-Delay was not intentioanal or deliberate-Assessee could not be prejudiced on account of an ignorance or error commistted by professional engaged by it-Delay is condoned. CIT(E) is directed to proceed with the return in accordance with law. [S.11, 119(2) Form No 10B, Art, 226]

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Order passed without considering relevant statutory provisions as will as judgements of various High Courts-Matter remanded to back to TPO for reconsideration in accordance with law.[Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Inconistent finding-Matter remanded to the Tribunal for considering appeal afresh.[S. 254(1),254(2, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Research and technical services-Comparable-Multi year data-Cannot be compared with companies which were doing business for many years. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Distribution and sale of cosmetic product-Comparable-Rule of consistency-Order of Tribunal rejecting the comparable is affirmed.[S.260A]

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)]