S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Most appropriate method-Acquisition of bundle of sports broadcasting rights-No comparable uncontrolled transaction prices available-Unique intangible asset-“other method” more appropriate. [S.92]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Purchases From AE-Sales By AE To Non-Related Parties-In one Month at price significantly higher than in other months-Difference in prices due to qualitative difference between ingots sold by AE to assessee and those sold to third parties-Substantial evidence to prove quality of products sold-No rationale in making adjustment only for one month-Reversal of adjustment is proper. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Selection of comparable-Turnover filter-Turnover of assessee 332 crores-DRP is justified in directing turnover of 200 crores to 2000 crores-Multiple of 10 times turnover could not be adopted. [S.92CA]

S. 92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-International transaction-Business profits-AO failed to demonstrate as to how payments / expenditure was unreasonable / more than FMV-Addition is deleted. [S.9(1))(i), 40A(2)(a), 40A(2)(b), 44BBB,,144C]

S. 90 : Double taxation relief-Non-resident-agreement with group entity in India-assesee supplying material as per agreement-roles of every member of the consortium agreed upon-assessee did not carry out operations in India-Held sums not taxable in India-DTAA-India-Chaina. [S.2(31)]

S. 90 :Double taxation relief-Filing of Form 67 is a procedural/ directory requirement-Non-filing of Form 67 within the prescribed due date would not extinguish the substantive right of claiming credit of foreign tax credit.[S.90A, R. 128,Form No 67]

S. 90 : Double taxation relief-Credit for foreign tax paid-Delay in filing Form No. 67-Directed the Assessing Officer to decide the claim of the foreign tax credit on merits, after accepting the Form No. 67 and other related documents filed by the assessee-DTAA-India-Netherland [S. 90A ,154, Form,67 R. 128(9) Art. 23]

S. 80P : Co-operative societies-Delay in filing of return-Failure to file the return on due date-Not entitle to deduction-Adjustment made while processing return of income is valid-Not entitled to deduction-Liable to pay fee of Rs 5000. [S. 80 (P) (2) (A) (i), 80AC, 139 (1), 139(4), 143 (1) (a) ,234F]

S. 80P : Co-operative societies-Belated return-Denial of deduction is not valid.[S. 139(1), 139 (4), 143(1)(a)(ii).]

S. 80P : Co-operative societies-Delay in filing of return-Dedcution cannot be denied .[S. 80IA,139(1), 139(4),143(1)(a)(ii) 143(1)(a)(v),153A]