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) ]

S. 80-O: Royalties – Foreign enterprises -Technical assistance- Principal agent relationship -Information concerning industrial, commercial or scientific knowledge, experience or skill- Major information sent by the appellant to the Sumitomo Corporation was in the form of blue prints for the manufacture of dies for stamping of doors which is not entitle to deduction .

S. 80M : Inter corporate dividends -Only the actual expenses for earning dividend income ought to be taken and not on estimate basis .