S. 234C : Interest-Deferment of advance tax-There was no tax due on returned income and hence, no interest could be levied.

S. 234A : Interest-Default in furnishing return of income-Taxes deposited before filing the return of income is more than the taxes finally determined on regular assessment, interest is not leviable.

S. 154 : Rectification of mistake–Refund of excise duty –Interest subsidy – Capital receipt. [S.145A]

S. 147 : Reassessment-Notice issued in the name of individual- Sanction was obtained in the name of firm-Reassessment is held to be bad in law –Not curable defects. [S. 148, 292BB]

S. 115JB : Book profit-Adjustments towards disallowance of amortization of subsidized cost-Different treatment given in the books of account-Adjustment is held to be not valid.

S. 92C : Transfer pricing—Selection of Comparables—Turnover filter— Analysis that smaller companies having less turnover could not be considered as comparable with assessee—Similarly, company who had more turnover than assessee could not be compared with assessee.

S.92C: Transfer pricing—Provision of software development services-Net Margin Method (TNMM) for benchmarking its international transaction of Provision of software development services-Working capital adjustment–Matter remanded.

S. 92C : Transfer pricing-Functionally different company cannot be selected as a comparable for arriving ALP of an international transaction.

S. 92C : Transfer pricing-Arm’s length price-Protective assessment by invoking Brightline method-Concept of ‘protective assessment’, as known to income tax law, had no application to assessee’s case- Merely because a binding judicial precedent from jurisdictional High Court had been challenged by revenue authorities before Supreme Court-Binding nature of a judicial precedent, as long as it hold field i.e. was not overturned, remained unaffected-Addition is deleted.

S. 92C : Transfer pricing-Capital or revenue-Adjustment On account of Advertisement, marketing and promotion (AMP) expenses- Roughly 60% of bills were furnished to AO in original proceedings- Matter remanded to AO for verification.