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]

S.90: Double taxation relief-Since, in terms of the permission of RBI, liaison office’s activities are confined to the liaison and representative activities and is not permitted to carry out any business/commercial activities in India, the said liaison office cannot be regarded as permanent establishment. [S.133A]