S. 119 : Central Board of Direct Taxes-Charitable Trust-Delay in filing Form No 10B-Delay of 1257 days-Oversght by the Chartered Accountant-Human error lacking any malafide intention-Delay was not intentioanal or deliberate-Assessee could not be prejudiced on account of an ignorance or error commistted by professional engaged by it-Delay is condoned. CIT(E) is directed to proceed with the return in accordance with law. [S.11, 119(2) Form No 10B, Art, 226]

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Order passed without considering relevant statutory provisions as will as judgements of various High Courts-Matter remanded to back to TPO for reconsideration in accordance with law.[Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Inconistent finding-Matter remanded to the Tribunal for considering appeal afresh.[S. 254(1),254(2, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Research and technical services-Comparable-Multi year data-Cannot be compared with companies which were doing business for many years. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Distribution and sale of cosmetic product-Comparable-Rule of consistency-Order of Tribunal rejecting the comparable is affirmed.[S.260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-Comparable-Employee cost filter-Different business model cannot be accepted as comparable-Extrodinary event of amlgamation cannot be accepted as comparable-Company engged in KPO services cannot be accepted as comparable. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Foreign AE can be taken as a tested party for purpose of establishing ALP of assessee.[S.92E, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-TNMM-CUP method-TNMM method is considered as most appropriate method-Order of Tribunal is affirmed-No substantial question of law.[S.260A, R.10B(2)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-AMP expenses-Bright Line Test (BLT) could not be applied for benchmarking AMP expenses-No substantial question of law.[S. 92B, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivable-Credit agreed between parties was 30 days-Extra credit allowed could be considered as an independent international transaction and same be compared with internal CUP being average cost of total funds available to assessee-SLP of revenue is dismissed due to low tax effect-Question of law is kept open. [Art.136]