S. 144C : Reference to dispute resolution panel-International Transaction-Limitation-Assessment order passed beyond one month from the end month in which directions of DPR received-Relaxation under TOLA Act not applicable-Assessment order barred by limitation. [S. 144C(13) 147]

S. 143(1)(a) : Assessment-Intimation-Prima facie adjustments-Business expenditure-Employees’ contribution to provident fund-Payment date beyond date but before filing of return of income-Auditor merely stating time of remittance in report-Contribution allowable.[S. 43B]

S. 127 : Power to transfer cases-Jurisdiction-CBDT Notification-Survey cases where material impounded to be centralised-Assessee case transferred thereof-AO aware of the transfer-Assessment by AO without jurisdiction-Order is without jurisdiction. [S.133A]

S. 115A : Foreign companies-Tax-Dividends-Royalty-Technical services fees-Non resident-Addition made under section 44DA.

S. 92CA : Reference to Transfer Pricing Officer-Arm’s Length Price-Payment to associated enterprise for services rendered-TPO cannot question necessity of expenses occurred-Assessee liable to prove that actual services rendered-Assessee failed to prove-no evidence or documentation or agreement between assessee and associated enterprise-No infirmity in the order of TPO-Arm’s length price-Nil.[S.37(1), 92C]

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax –Adopted Transactional net margin method in previous years-Adopted Internal comparable uncontrolled price method in subsequent years as most appropriate-No explanation-Matter remanded to T.P.O to reconsider transfer pricing adjustment to justify appropriate method.

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax Reference to Transfer Pricing-Loan to overseas subsidiaries in foreign money-Interest to be estimated as foreign-currency loan and not rupee denominated loan-International libor rates to be taken as benchmark.

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Royalty-Assessee earning brand royalty from associated enterprise-Royalty to be quantified in terms of order for earlier years-Service fees at Ad hoc rate to be restricted.

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.