S. 271G : Penalty – Documents – International transaction – Transfer pricing – Conduct of Assessee can be considered as a reasonable act of an organization acting with prudence under normal circumstances without negligence or inaction or want of bonafides, hence no penalty u/s 271G can be invoked.

S. 268A : Appeal – Application – Reference – Instructions -CBDT Circular – Low tax effect – Tribunal dismissed the appeal on disallowance u/s. 14A. Since the Tribunal recorded findings only on the interpretation of the contents of the Circular No. 5/2014 dealing with disallowance u/s. 14A, the said findings cannot be regarded as the Tribunal declaring the CBDT Circular No. 5/2014 either as illegal or ultra vires.[ S. 253, 260A ]

S. 260A : Appeal – High Court – Additional ground – Revision order was passed in the name of dead person – Matter remanded . [ S. 263 ]

S. 201: Deduction at source – Failure to deduct or pay – assessee made ad-hoc provisions of expenses in respect of various services received to facilitate closing of the books without reference to any particular party – No deduction towards the expenditure was claimed under these provisions – Proceedings under section 201 / 201(1A) unjustified. [S. 40(a)(ia)]

S. 158BD: Block assessment – Undisclosed income of any other person – Agreements with the distributors conferring distribution rights of film – Entire amount received prior to release of the film – Entire amount is liable to be offered for tax. [S. 158BC]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Firm dissolved – Department is intimated – Transaction recorded in proprietorship concern – Matter remanded for fresh consideration [ S. 148, 148A(b) 148A(d), Art , 226 ]

S. 148 : Reassessment –Notice – Failure to serve a copy of the Notice issued u/s. 148 before passing the re-assessment order would render the order as infructuous- Appeal filed by Revenue dismissed since no substantial question of law arise- Section 292BB was inserted in the Act in 2008 and cannot be given retrospective effect. [ S. 147, 292BB ]

S. 147 : Reassessment – Bad debt – Involved mixed questions of fact and law as to validity of reopening and taxability of amount received under debt waiver scheme, the High Court was not a proper forum to decide such mixed question and matter was to be remanded back to AO.[ S. 36(1)(viia), 254(1), 260A]

S. 115JB : Provisions of section 11JB will not apply to the taxpayer being a corporation established under Damodar Valley Corporation Act, 1948.[ Damodar Valley Corporation Act, 1948 ]

S.115BAA : Tax on income of certain domestic companies – Omission to file Form No 10IC – Directed to file an appropriate application in writing addressed to the Principal Chief Commissioner / Chief Commissioner making a request to permit it to file the Form 10IC electronically after condoning the delay in that regard so that the return of the Assessee can be re-processed or regular assessment can also be framed accordingly. [ S.115BA, 115BAB, 119(2)(b), Form No 10IC , Art , 226 ]