S. 144C : Reference to dispute resolution panel-Limitation-Transfer Pricing Officer to pass order at any time before 60 days prior to limitation-Order is barred by limitation. [S. 92CA(3A), 153]

S. 144C : Reference to dispute resolution panel-International Transactions-Transfer Pricing-Limitation-Assessment not completed within 21 months from end of Assessment Year plus extension of 12 months for transfer pricing reference-Assessment is barred by limitation-Order is invalid-Draft Assessment order-Eligible assessee-Order is quashed. [S.92CA, 114(15)(b)(ii), 153]

S.143(3): Assessment-Income from undisclosed sources-Scrap-Methodology in determination of average sale of scrap per day and making addition is against established trade practices-Deletion of addition is affirmed. [S.69]

S. 143(3): Assessment-Income from undisclosed sources-Cash deposits in Account-Land aggregator-Failure to response to notice by the builder-Addition is affirmed.[S.44AD]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Companies whose segmental data not available, having functional disparity with assessee, undergoing extraordinary event of amalgamation are to be excluded from list of comparables-Profit level indicator-Service tax refund or service tax written back is operating revenue.[S. 144C(13)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-A Group Concern of foreign company, Business process outsourcing and knowledge process outsourcing-Comparables-Functional dissimilarity and absence of segmental data-Turnover of company more than 14 times to be excluded from list of comparables.-Ad hoc two per cent. for working capital adjustment-Remanded to transfer pricing officer to adopt reasonable percentage on actual basis based on data available on record.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-A Group Concern of foreign company, Business process outsourcing and knowledge process outsourcing-Comparables-Functional dissimilarity and absence of segmental data-Turnover of company more than 14 times to be excluded from list of comparables.-Ad hoc two per cent. for working capital adjustment-Remanded to transfer pricing officer to adopt reasonable percentage on actual basis based on data available on record.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Commission on standby letter of credit-No cost is incurred-Adjustment is deleted.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on loan given to Associated Enterprise-Interest in terms of safe harbour rules acceptable-Arm’s Length price adjustment is to be made accordingly. [S.92B, 92CA, R. 10TD(2A)(5)]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Interest on trade receivables-Interest rate on similar foreign currency receivables and advances as Libor + 200 Points-Adjustment on account of interest on trade receivables unwarranted-Payment for global and regional management-Restored to Assessing Officer for fresh factual verification.[S.92C]