S. 201 : Deduction at source-Failure to deduct or pay-Survey-Rural bank-Non submission of Form 15G and Form 15H-Collected more than 75 percent of Forms-Order levying interest is set aside. [S. 133A, 197A, 201, 201(IA), Form No 15G, 15H, Regional Rural Banks Act]

S. 195 : Deduction at source-Non-resident-Right to use software-Not royalty-Not liable to deduct tax at source. [S. 9(1)(vi), Copy Right Act, 1957, S. 14(b)]

S. 149 : Reassessment-Time limit for notice-Amendment to section 149(1), introduced with effect from 1-4-2012, providing longer time limit of 16 years for reopening assessments in foreign asset cases is expressly stated to be retrospective in nature. [S. 143(3), 147, 149(1)(c)]

S. 147 : Reassessment-Income deemed to accrue or arise in India-Permanent Establishment-Notice based on the assessment orders of earlier years orders is held to be not valid. [S. 9(1)(i), 148]

S. 144C : Reference to dispute resolution panel-Order passed without following the directions of DRP-Order was set aside. [S. 92C 144C(5)]

S. 144C : Reference to dispute resolution panel-Failure to pass draft assessment order-Violation of procedure-Order set aside. [S. 144C(13), 271(1)(c)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Distribution of products-Royalty paid by assessee would be within arm length range and impugned ALP adjustments were deleted-Merchandise and samples from its AE for resale in India-Resale Price Method (RPM) is Most Appropriate Method (MAM) to benchmark said international transaction.

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustments-Working capital adjustment to be allowed where TNMM used for calculation of ALP. [R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Export filter-filter of 10 per cent as applied by assessee was most reasonable-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Trading goods-Capitalised goods-Adjustment was deleted-Adjustment of interest-Delay in realization of invoices raised on AE-Matter remanded to the AO.