S. 195 : Deduction at source-Non-resident-Right to use software-Not royalty-Not liable to deduct tax at source. [S. 9(1)(vi), Copy Right Act, 1957, S. 14(b)]

S. 149 : Reassessment-Time limit for notice-Amendment to section 149(1), introduced with effect from 1-4-2012, providing longer time limit of 16 years for reopening assessments in foreign asset cases is expressly stated to be retrospective in nature. [S. 143(3), 147, 149(1)(c)]

S. 147 : Reassessment-Income deemed to accrue or arise in India-Permanent Establishment-Notice based on the assessment orders of earlier years orders is held to be not valid. [S. 9(1)(i), 148]

S. 144C : Reference to dispute resolution panel-Order passed without following the directions of DRP-Order was set aside. [S. 92C 144C(5)]

S. 144C : Reference to dispute resolution panel-Failure to pass draft assessment order-Violation of procedure-Order set aside. [S. 144C(13), 271(1)(c)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Distribution of products-Royalty paid by assessee would be within arm length range and impugned ALP adjustments were deleted-Merchandise and samples from its AE for resale in India-Resale Price Method (RPM) is Most Appropriate Method (MAM) to benchmark said international transaction.

S. 92C : Transfer pricing-Arm’s length price-Working capital adjustments-Working capital adjustment to be allowed where TNMM used for calculation of ALP. [R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Comparables-Export filter-filter of 10 per cent as applied by assessee was most reasonable-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Trading goods-Capitalised goods-Adjustment was deleted-Adjustment of interest-Delay in realization of invoices raised on AE-Matter remanded to the AO.

S. 92BA : Transfer pricing-Domestic transactions-Vide amendment by Finance Act, 2017, clause 6) of section 92BA had been omitted from 1-4-2017, it would be deemed that clause 6 has never been on statute and since nothing was specified whether proceeding initiated or action taken on this would continue, proceeding initiated or action taken under that clause would not survive. [S. 92C]