S.92C: Transfer pricing – Arm’s Length Price – Difference in function performed and risk undertaken – Difference in brokerage charged to related and un related parties –Deletion of addition was held to be justified

S.92C: Transfer pricing – Arm’s Length Price – Corporate guarantee- When no expenditure was incurred for providing guarantee to bank for the loan given to subsidiaries applying the rate of 2.5% by the TPO was held to be not justified .

S.92C:Transfer pricing – Arm’s length price –Method of accounting – TPO has no jurisdiction to comment on the method of accounting followed by an assessee. [ S.145 ]

S.92C: Transfer pricing – Arm’s length price- The TPO can not sit in judgement over the business model of the assessee and determine the ALP of the transactions with AEs at Nil .

S. 92: Transfer pricing -International transactions — Arm’s length price — Transaction of sale of shares in Indian company to be benchmarked under transfer pricing provisions. [S. 92A to 92F ]

S. 92: Transfer pricing -International transactions — Arm’s length price — Transaction of sale of shares in Indian company to be benchmarked under transfer pricing provisions. [S. 92A to 92F ]

S. 90: Double taxation avoidance -Income deemed to accrue or arise in India – Capital gains-Transfer of shares by German individuals to German Company – Not liable to deduct tax at source-DTAA-India – Germany . [ S. 45, 90 , 195 , Art, 13 ]

S. 90: Double taxation relief – Non –resident – Assessee is not operating as independent entity-Assessee is not entitled to benefit of double taxation avoidance agreement between India and Mauritius.- Transaction was held to be liable to tax in India and tax to be with held – DTAA-India –Mauritius- USA [S. 195, Art. 13 ]

S. 90: Double taxation avoidance agreement -Income – Non –resident -Capital gains, arising from sale of shares in Indian Company to group company in Singapore is not Liable to tax in India —DTAA-India –Mauritius [S. 195, Art. 13 ]

S. 80P : Co-operative societies- Co –Operative Society is not a Credit Co-Operative Bank- Entitle deduction .[ S.80P(2)(a)(i) (4) ]