S. 92CA : Reference to transfer pricing officer-Time-Limit for to pass order-Sixty days to be computed excluding last date for passing order-Order passed beyond limitation period of 60 days-Order is bad in law-Appellate Tribunal has the power to admit the additional ground raised as to jurisdiction. [S. 92CA(3), 143(3), 153, 254(1)]

S. 92C : Transfer pricing-Arms’ length price-safe harbour rules are optional for an eligible assessee-assessee has not exercised option for the safe harbour rules-entire set of rules from 10TA to 10TG cannot be operationalised. (ITR, 10B(1)€ & 10 TA)

S. 92C : Transfer pricing-Arm’s length price-Transfer Pricing adjustment cannot extend to non-AE transactions and to that extent a proportionate adjustment is warranted.

S. 92C : Transfer pricing-Arm’s length price-Depreciation adjustment can be allowed for computation of operating profit, only if there is variance in the depreciation rates applied with the comparable. [S. 32]

S. 92C : Transfer pricing-Arm’s length price-Depreciation adjustment can be allowed for computation of operating profit, only if there is variance in the depreciation rates applied with the comparable. [S. 32]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Authorities justified in adopting combined accounts approach and confining addition to export segment-Functional similarity-Low turnover-Matter remanded-Draft Assessment order-Assessing Officer bound to follow Dispute Resolution Panel’s Direction. [S. 144C]

S. 92B : Transfer pricing-The term international transaction includes capital financing, which, in turn, also includes guarantee-effects of furnishing corporate guarantee directly percolated to the principal debtor, namely, AE for whom the assessee stood surety-thus, the department contention that the act of furnishing guarantee be treated as shareholder’s activity, is devoid of any merit. [S. 92C, 92CA]

S. 92A : Transfer pricing-Associated enterprises-Arm’s Length Price-Tested party to be determined even when most appropriate method was comparable uncontrolled price-Generation of power for captive consumption-Rate to be taken at rate supplied by Electricity Board to its consumers in open market. [S. 80IA(8), 92CA]

S. 80IB(10) : Housing projects-Survey-On money-Sale of flats-Entitle to deduction. [S. 133(6)]

S. 73 : Losses in speculation business-Share broker-Purchase and sale of shares-Loss incurred from error trades-Not speculative-Allowable as business loss. [S. 28(i)]