S. 115JB : Book profit-Provision for diminution in value of investment-Written off in books of account-Addition cannot be made. [S. 115JB(2)(i)]

S. 115BBE : Tax on specified income-set-off of any loss-Entitled to claim set-off of loss against income determined under till assessment year 2016-17. [S. 68 to 69D]

S. 92C : Transfer pricing-Arm’s length price-Advertisement expenses-No agreement between AE-Adjustment was deleted-adjustment of royalty was deleted.

S. 92C : Transfer pricing-Arm’s length price-Factors to be considered while accepting comparables-Web enabled customer care services, BPO services-Health care BPO services-Revenue filter-Held to be not comparable-Turnover of comparable company was 509 times-Not comparable-High Brand value-Not comparable.

S. 92C : Transfer pricing-Arm’s length price-Functional similarity-Business of manufacturing and distributing products of consumer electronics and home appliances category-Providing an online marketing platform for sale of electronic products of multiple brands-Designing and manufacturing of only mobile phones-Having brand owning and outsourcing its manufacturing activities to third party contractors could not be accepted as a valid comparable-Would not be accepted as a valid comparable.

S. 92C : Transfer pricing-Arm’s length price-Export of customers electronic data-Comparable-Functionally different-Not acceptable as comparable-Interest receivable-No separate adjustment for interest on receivable was to be made.

S. 92C : Transfer pricing-Arm’s length price-Restricted to international transactions with Associated Enterprises.

S. 92C : Transfer pricing-Arm’s length price-TNM method-Cost plus method-TNM was directed to be applied-Beneficiary of AMP expenses or promotion of brand, said transfer pricing adjustment was to be deleted-Adjustment of royalty-Directed to be deleted.

S. 92C : Transfer pricing-Arm’s length price-Profit Split Method Royalty and AMP expenses-Required to be shown separately-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally similarity-Safe to exclude it from final list of comparables to assessee who had been following fixed price project model-turnover filter of Rs. 1 crore, companies having turnover of more than Rs. 200 crores have to be excluded.