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.

S. 92BA : Transfer pricing-Domestic transactions-Vide amendment by Finance Act, 2017, clause 6) of section 92BA had been omitted from 1-4-2017, it would be deemed that clause 6 has never been on statute and since nothing was specified whether proceeding initiated or action taken on this would continue, proceeding initiated or action taken under that clause would not survive. [S. 92C]

S. 80P : Co-operative societies-Letting of godown-Milk parlours cannot be considered as godowns or warehouses as contemplated under section 80P(2)(e) and hence, rental income derived from letting of milk parlours will not be eligible for deduction under section 80P(2)(e) of the Act. [S. 80P(2)(e)]

S. 80P : Co-operative societies-Interest-Bank-Bank not being a co-operative society interest income could not be said to attributable to activities of co-operative society-Not eligible for deduction-Interest income reduced by administrative expenses and other proportionate expenses to earn said income had to be brought to tax as income from other sources. [S. 56, 57, 80P(2)(d)]

S. 80IA : Industrial undertakings-Infrastructure development-Partnership firm-Executed works contract-Not eligible deduction [S. 800IA(4), 80IA(13)]

S. 80G : Donation-Expenses incurred under Corporate Social Responsibility Scheme under provisions of Companies Act are eligible for deduction-Matter remanded. [S. 37(1)]

S. 80G : Donation-CSR expenses-Denial of deduction merely because donation forms part of CSR as it would lead to double disallowance is held to be not valid. [S. 37(1)]