S. 147 : Reassessment – Survey -Non disclosure of Royalty and FTS in the original return-Reassessment is held to be justified. [S. 133A, 148]

S. 147 : Reassessment–Notice-License fee-Use of logo -Capital or revenue – Reopening solely based on audit objections not permitted as it amounts to change of opinion. [S. 37(1), 147]

S. 147 : Reassessment–Based on subsequent finding of DRP that there was no Permanent Establishment of the assessee in India– AO dropped reassessment proceedings–Order passed by High Court upholding validity of those proceedings was to be set aside. [S. 148]

S. 132A : Powers-Requisition of books of account–Reasons to believe to issue requisition notice not required to be disclosed to any person or Authority or Appellate Tribunal. [S. 254(1)]

S. 92C : Transfer pricing-Arms’ length price–Selection of comparables-Remand to the AO-Held to be proper. [S. 254(1)]

S. 92C : Transfer pricing-Arms’ length price–Tribunal’s remand for ALP determination on a combined basis not an academic exercise- Order of Tribunal is affirmed. [S. 254(1)]

S. 92C : Transfer pricing-Interest chargeable on delayed recovery of export receivables and expenses–LIBOR rates should be taken instead of SBI PLR. [S. 144C]

S. 69 : Unexplained investments–Unable to rebut a statement made against him and failure to explain the source- Statement could not be read in piecemeal depending on what part suits to the assessee and what part does not – Addition is held to be justified. [S. 131]

S. 68 : Cash credits–Advance received back -Source of money was sufficiently explained-Addition is held to be not justified.

S. 68 : Cash credits – Identity of the depositor, genuineness of the transaction- Onus discharged – Deletion of addition is held to be justified.