S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-The benchmarking has to be done based on the prevailing market rate which a normal bank would lend money with the minimum risk. Since the assessee has already mitigated the risk by investing in the fully convertible debentures when the risk is already mitigated one more time, the same risk element cannot be considered for bench marking on the interest payment also. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Application of turnover filter-Higher threshold limit of INR 200 crores-Excluded. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on delayed receivables, credit period on invoices-interest on overdue export proceeds not charged from associated and non-associated enterprise-independent third parties on the similar transaction with a similar credit period of similar goods no interest charged-transfer pricing officer deleted adjustment. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Adjustment on account of interest paid on fully convertible debentures. [S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-ALP on combined transaction basis. ALP on combined transaction basis. [R.10A(d)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Companies with higher turnover to be excluded-Organisation for Economic Co-Operation and Development guidelines to be followed-Working capital adjustment to be allowed.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Outstanding receivables-Directed to frame fresh computation.[S.92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Selection of Comparable-Transactional net margin method-Functionally dissimilar-Software Services-Company engaged in diversified activities but segmental details relating to various segments not available in public domain and providing technical services-Cannot be taken as comparable.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Selection of comparables-Turnover filter-Companies whose Turnover not within range of Rs. 200 Crores to Rs. 2,000 Crores-Company having abnormally high margin-Not functionally Comparable to be excluded.

S.90: Double taxation relief-Non discrimination clause-Income to be taxed at the rate 30 % instead of 40% (Plus surcharge and education cess)-DTAA-India-Korea [S.9(1)(i), Art. 7(2), 24]