S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Advertisement and sales promotion expenses-Reimbursement expenses-Royalty-Business expenditure-Allocation of expenses-Additional evidence-Bench marking of expenses-Advances written off-Subsidy-Royalty-workmen-Number of days. [S.4, 28(i), 36(1)(vii),37(1), 80JJAA, R. 10B(1)(a)]

S. 92C : Transfer pricing-Arm’s length price-Selection of comparable-Turnover filter-Turnover of assessee 332 crores-D.R.P justified in directing turnover of 200 crores and less than 2000 crores.

S. 92C : Transfer pricing-Arm’s length price-Determination-Payment of interest on compulsorily convertible debentures-Cannot be regarded as loan-Interest cannot be computed on libor-Interest rate of 9 and 12 percent justified.[S.92]

S. 92C : Transfer pricing-Arm’s length price-Royalty-Engaged in the business of industrial gases through plant operated with technical assistance from associated enterprise-Payments made to associated enterprise-Royal at 4% on sales to be taken as arm’s length-No contrary evidence to disregard factum of technical services rendered by associated enterprise-Computation of 1% fess by A.O. as arm’s length adhoc-Not sustainable-Matter remanded. [S. 92]

S. 92C : Transfer pricing-Arm’s length price-Fee for corporate guarantee-0.5%-Specified Domestic Transaction-Transfer of power from eligible units to manufacturing units-Adjustment to be deleted.

S. 92C : Transfer pricing-Arm’s length price-Interest on receivables-Not a separate international transaction-Net margin more than of comparables-Separate Benchmarking not required. Adjustment to be deleted.

S. 92B : Transfer pricing –Arm’s Length Price-Interest free loans to Associated enterprise-Adjustment on account of provision of bank guarantee to associated enterprises-No income earned and commercial expediency not relevant-Adjustment at 0.5% instead of 1.3%.

S. 80IC : Special category States-Industrial Undertaking-Special deduction-Income from undertaking-Interest earned from FDs-Inextricably linked to business activity as maintenance of FDs-Entitled to deduction.

S. 80IC : Special category States-Special deduction-Apportionment of head office expense among eligible units not justified-No nexus with eligible units. [80IB]

S. 80AC : Return to be furnished-Co-operative society-Return to be filed within due date-Failure of-Not entitled to deduction-Adjustments to be made while processing return of income. [S. 80 (P) (2) (a) (i), S. 139 (1), 139 (4), 143 (1) (a)]