S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Research and technical services-Comparable-Multi year data-Cannot be compared with companies which were doing business for many years. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Distribution and sale of cosmetic product-Comparable-Rule of consistency-Order of Tribunal rejecting the comparable is affirmed.[S.260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-Comparable-Employee cost filter-Different business model cannot be accepted as comparable-Extrodinary event of amlgamation cannot be accepted as comparable-Company engged in KPO services cannot be accepted as comparable. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Foreign AE can be taken as a tested party for purpose of establishing ALP of assessee.[S.92E, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-TNMM-CUP method-TNMM method is considered as most appropriate method-Order of Tribunal is affirmed-No substantial question of law.[S.260A, R.10B(2)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-AMP expenses-Bright Line Test (BLT) could not be applied for benchmarking AMP expenses-No substantial question of law.[S. 92B, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivable-Credit agreed between parties was 30 days-Extra credit allowed could be considered as an independent international transaction and same be compared with internal CUP being average cost of total funds available to assessee-SLP of revenue is dismissed due to low tax effect-Question of law is kept open. [Art.136]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Generation of power-Interest on Bonds issued by Grid Corporation in lieu of unpaid energy bills-Eligible for deduction-Order of High Court affirmed-SLP of Revenue is dismissed. [S. 80IA (iv)(a),80IB, 80IC, Art. 136]

S. 69C : Unexplained expenditure-Bogus purchases-Order of Tribunal restricting 8 % of purchase is affirmed. [S.260A]

S. 69C : Unexplained expenditure-Bogus purchases-Statement of director-No independent enquiry was made-Deletion of addition by the Tribunal is affirmed-No substantial question of law. [S. 132, 143(3), 260A]