S. 43(5) : Speculative transaction – Derivatives-Loss incurred on future and option is deemed to be business loss- Loss would be set off against income from business- Explanation to S.73 is not applicable [ S.73 ]

S. 14A : Disallowance of expenditure – Exempt income – Disallowance cannot exceed the exempt dividend [ R.8D ]

S. 10AA : Special economic zones – Interest on capital and remuneration-Partnership deed is not providing any interest- AO cannot disallow the interest and remuneration and reduce the eligible exemption .[ S.80IA ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection -Capital gains – Sale of shares- DTAA-India – Spain [ Art .14(6) ]

S. 2(22)(e):Deemed dividend- Share holder-Can be assessed only in hands of a person who is a share holder of company and not in hands of a person other than a share holder . [ S.2(32) ]

S. 254(2):Appellate Tribunal-Rectification of mistake apparent from the record –Failure to deal with an argument does not constitute a ‘mistake apparent from the record’ does not apply to a case where a fundamental submission is omitted to be considered by the ITAT- The omission is apparent from the record and should be rectified by the ITAT .The Tribunal ought to have decided the issue of the character of distribution fees, whether royalty or not, as all the facts were available on record before it and the submissions also were made, rather than remanding the issue to the Transfer Pricing Officer. .

S. 147:Reassessment- With in four years-Intimation- Wrong recording of reasons – order on disposal of objections must deal with the objection- The mere fact that the return is processed u/s 143(1) does not give the AO a carte blanche to issue a reopening notice-.Reassessment notice is quashed [ S.143(1), 148 ]

S.147: Reassessment-After the expiry of four years- Bogus sales and purchases – Dealer in iron and steel- If the AO disallowed 2.5% of alleged bogus purchases during the regular assessment-Reassessment to disallow entire amount is said to be bad in law- There is difference between revisional powers and reassessment . [ S. 68, 69 148, 263 ]

S. 144C : Reference to dispute resolution panel – Final order passed by the AO which was sought to be corrected by issue of corrigendum – Time to pass draft assessment order had expired – Order passed was without jurisdiction.[ S.92C, 153A(2A) ]

S.147: Reassessment-After the expiry of four years- Finding in case of another assessee- No failure to disclose material facts – Reassessment is not valid. [ S. 80IB(10),148 ]