S. 144C : Reference to dispute resolution panel-Non-speaking order-Matter remanded. [S. 92C]

S. 143(3) : Assessment-Estimate of income-The AO cannot make addition on estimate basis when no specific defect or infirmity in the books of account maintained by the assessee. [S. 145]

S. 142A : Estimate of value of assets by Valuation Officer-Under valuation-Capital gains-Valuation as on 1-4-1981-Reference to Valuation Officer is held to be not valid. [S. 45, 55A(b)(i), 69, 69A, 69B].

S. 115JB : Book profit-Profit on sale of Agricultural land-Cannot be added to book profit. [S. 2(IA)]

S. 115JB : Book profit-Exempt income-Disallowance u/s. 14A read with Rule 8D cannot resorted while determining the book profit. [S.14A , R.8D]

S. 92C : Transfer pricing-Arm’s length price-Reimbursement of expenses-Bright-Line Text (BLT)-Interest-TPO could not have determined 30 days as credit period for computing interest on outstanding receivables, without appreciating actual credit terms offered to AEs.

S. 92C : Transfer pricing-Arm’s length price-Turnover filter-To be accepted as valid comparable.

S. 92C : Transfer pricing-Arm’s length price-Comparble-Customised software development on contractual basis Job placement portal and BPO services-Dissimilarity in functions and for want of segmental accounts-Sponsorship fees and other expenses, said company was to be excluded from final set of comparables-Turnover more than 750 time cannot be considered as comparable-Profit margin-Sale of licence-Sale of software and products.

S. 92C : Transfer pricing-Arm’s length price-Software development-Directed to pass speaking order-Working capital-computed by taking actual data without putting any upper limit-Ad-hoc estimate of risk differential was directed to recompute. [S. 144C]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Functionally different-Companies having turn over of 10 times greater cannot be considered as comparable companies.