S. 115JB : Book Profit–Provision for warranty-Followed scientific method and had considered historical data to arrive at correct book profit- Addition of provision for warranty would not be justified.

S. 115JB : Book Profit – Exempt income -No disallowance to be made under S. 14A while computing book profit. [S. 14A]

S. 92C : Transfer pricing – Arms’ length price – In order to analyze ALP of international transactions, closely linked transactions were to be adopted as one transaction in order to carry out TP analysis by applying any of the prescribed methods as appropriate method-Matter remanded.

S. 92C : Transfer pricing – Arms’ length price – Royalty paid to associated enterprises was same as assessed when it was an independent entity – No adjustment to be made.

S. 92C : Transfer pricing – Arm’s length price – comparables- Segmental information is not provided by company in respect of software services, same could not be included as a good comparable-Functionally indifferent companies cannot be selected as good comparable- Fact that a company had a high or low turnover could be no reason to justify its exclusion if it was otherwise functionally comparable.

S. 92B : Transfer pricing–International Transaction–Advertising Marketing and Promotion (AMP) expenses is not an international transaction- Adjustment is held to be not justified. [S. 92C]

S. 80IA : Industrial undertakings–Captive consumption-Power supplied to its divisions -Market value of power supplied to others to be charged

S. 80IA : Industrial undertakings–Loss of an eligible industrial unit is not required to be set-off against profit of other eligible unit

S. 45 : Capital gains- Business income -Short term gains on sale of shares and mutual funds – Rule of consistency is directed to be followed-Assessed as capital gains. [S. 28(i), 111A]

S. 43D : Public financial institutions–Interest income on loans categorised as NPA/sticky loans–Taxable on receipt basis and not on accrual basis. [S. 145]