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)]

S. 72 : Carry forward and set off of business losses-Set off of loss returned by Assessee in subsequent assessment years could not be declined only for the reason that assessment for assessment year in which the losses arose, was in progress and pending. [S. 240]