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]

S. 80P : Co-operative societies-In the absence of evidence to prove that trading of agricultural equipment was done with persons other than the members, deductions cannot be disallowed. (ii) Section 80P of the Income Tax Act, 1961: State Government grants are eligible for deduction under the section provided the same is disbursed to members of the society only. (iii) Section 80P of the Income Tax Act, 1961: Receipts incidental to the main activities of the business also are eligible for deduction under section 80P of the Act. [S.80P(2)(a)(iii), 80P(2)a)(iv)]

S.80P: Co-operative Societies-Interest income earned from investments made with co-operative banks allowed as deduction. [S.80P(2)(d)]