S. 115-O : Domestic companies-Tax on distributed profits-Complete Code-DTAA does not get triggered at all when a domestic company pays DDT under section 115-O-Where contracting states to a tax treaty intend to extend treaty protection to domestic company paying dividend distribution tax, only then, domestic company can claim benefit of DTAA, if any-Machinery provision for recovery-Benefit of DTAA-DTAA-India-Fraance [S. 2(24)(ii),2(43), 4, 9(1)9iv), 90(2),115P, 115Q Art. 10, 26(1), 26(4), 26(5)]

S. 115JB : Company-Book Profits-Assessing Officer without discussion computing book profits at higher figure than that computed by assessee-Difference representing provision for current tax-Assessee declaring net amount instead of reporting each item separately-Order set aside and matter remanded to AO for adjudication afresh-Claim under section 80JJAA is also set asde.[S.80JJA]

S. 115JB : Company-Book profit Computation under clause (f) of Explanation (1) to section 115JB(2) of the Act, is to be made without resorting to the computation as contemplated u/s. 14A of the Act .[R.8D]

S. 115JB : Company-Book profit Unabsorbed depreciation-Adjustment of carried forward business loss or unabsorbed depreciation which ever is lower for purposes of section 115JB .[S. 32 (2), 72, 115JB(2)]

S. 115BBE : Tax on specified income-Determination of tax in certain cases-Unexplained income-Rate of tax-Assessee did not maintain proper books of account-Excess stock and receivables on account of unaccounted sales and cash generated on account of unaccounted sales was found in survey-Assessee’s explanation accepted by survey party-Additional income surrendered by assessee not from unexplained source but from business proceeds-Under peculiar facts surrendered income to be taxed at normal rate applicable to business income and not at higher rate of sixty per cent:

S. 115A: Foreign companies-Tax-Dividends-Royalty-Technical services fees-Non-resident-Fees For Technical Services-Special rate of tax-Contract, right or property to be effectively connected-Fees for technical services taxable at special lower rate-The addition made under section 44DA of the Act is deleted.[S.44DA]

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Order of Transfer Pricing Officer-Limitation-Period of sixty days to be counted from day prior to date on which period of limitation for assessment expires-Order barred by imitation by one day-Order non est-Assessee ceases to be eligible assessee-Draft assessment order and assessment order void ab initio.[S. 144C, 153]

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Survey-Notices issued to assessee calling for evidence and explanation with respect to Transfer Pricing Adjustment Proposed By Transfer Pricing Officer-Failure to furnish details bbefore Assessing Officer-Failure by Assessee to comply with notices issued in spite of several opportunities-Opportunity may be provided to assessee to present its case before Assessing Officer-Assessee to pay cost Rs. 25,000 in each appeal. [S. 92CA (3), 133A, 142(1), 144C]

S. 92CA : Reference to Transfer Pricing Officer-Arm’s Length Price-Payment to associated enterprise for services rendered-TPO cannot question necessity of expenses occurred-Assessee liable to prove that actual services rendered-Assessee failed to prove-no evidence or documentation or agreement between assessee and associated enterprise-No infirmity in the order of TPO-Arm’s length price-Nil.[S.92C]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-AO drawing an adverse inference without providing an opportunity to explain the working of allocation is in violation of principals of natural justice. [S. 144C]