S. 92C : Transfer pricing-Arm’s length price-Related transactions constituted 96.30 per cent of total turnover for which margin was agreed to be 15.85 percent under MAP resolution-Same rate to be applied for non USA related transactions under EDS segment.
S. 92C : Transfer pricing-Arm’s length price-Resale Price Method (RPM)-Resale of goods imported from its AE to third party customers without any value addition-Resale Price Method (RPM) is Most Appropriate Method (MAM).
S. 92C : Transfer pricing-Arm’s length price-Comparable-Filter-Filter applied by TPO was to be included in list of comparables regardless of fact that it was low margin earning company.[S. 133(6)]
S. 92C : Transfer pricing-Arm’s length price-CUP method-Applying of ‘QUOTE’ from third party for economic analysis using CUP method was not a justifiable method-Matter remanded.
S. 90 : Double taxation relief-Foreign Tax credit-Salary income-Rule 128(9) of Rules does not provide for disallowance of Foreign Tax Credit in case of delay in filing Form No. 67,-Filing of Form No. 67 is not mandatory but a directory requirement-DTAA-India-Australia. [S. 91, 139(1), 154, 192, R. 128(9), Form no. 67, Art. 24(4)(a)]
S. 80IA : Industrial undertakings-Infrastructure development-loss of one eligible unit is not to be adjusted or set off against profit of another eligible unit-Captive power plant-Market value of power supplied by assessee to steel division should be computed considering rate of power charged by Chhattisgarh State Electricity Board for supply of electricity to industrial consumers.
S. 80GGC : Contribution-Political parties-Failure of done to use it for object for which eligible-No disallowance can be made in the hands of donor.
S. 69C : Unexplained expenditure-Bogus purchases-Sales accepted-Disallowance restricted to 12.5 % of aggregate value of alleged bogus purchases.
S. 68 : Cash credits-Share application money-Not furnished explanation about nature and source of credit-Addition is confirmed.
S. 56 : Income from other sources-Fair market value of property-Purchase of property-Stamp valuation-Addition was not valid-Matter remanded. [S. 56(2)(vii)(b)(ii)]