S. 92C : Transfer pricing–Arm’s length price–No transfer pricing adjustment can be made on transactions with the non-AEs– Matter remanded.

S. 92C : Transfer pricing–Arm’s length price–LIBOR instead of LIBOR + credit spread on account of the risk profile of the borrower.

S. 92C : Transfer pricing–Arm’s length price–Loan to AE-Interest should be charged at LIBOR+200 bps.

S. 92C : Transfer pricing–Arm’s length price–Comparable-Directed the TPO to compute margins by taking foreign exchange fluctuations gains/loss as part of operating income both in the case of the assessee and comparable companies.

S. 92C : Transfer pricing–Arm’s length price–Additional evidence was produced–Matter remanded. [S. 254(1)]

S. 92C : Transfer pricing–Arm’s length price–DRP was right in law in accepting the contention of assessee to grant custom duty adjustment, when the assessee has worked out the adjustment in its own hands while as per Rule 10B(1)(e)(iii), if any adjustment is to be made it should be made in the hands of comparable companies only.

S. 92C : transfer pricing–Arm’s length price–Professional fees-TNMM-CUP method–Matter remanded to the TPO.

S. 92B : Transfer pricing–Corporate guarantee-International transaction-Directed to take 1% as arm’s length price. [S. 92C]

S. 70 : Set off of loss–Long term capital loss against long term capital gains-Long term capital loss arising out of sale of shares cannot be set off against long-term capital gain from sale of shares subjected to STT and claimed exempt u/s. 10 (38)-Directed the AO to allow carry forward of long term capital loss as claimed by the assessee.[S. 2(14) 10(38), 45, 74]

S. 69 : Unexplained investments–Income from undisclosed source-Alleged sale of scraps-Addition is held to be not justified.[S. 4, 145]