S. 147 : Reassessment-After the expiry of four years-Stock in trade – Debit of purchase of traded goods-In the original assessment proceedings profit and loss account was thoroughly scrutinised by the AO-No failure to disclose on part of assessee to produce all material particulars during original assessment proceedings-Notice for reassessment is held to be not valid. [S. 68, 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years- Information from DDIT (investigation)–Purchasing and selling of shares- Systematic evasion of taxes by clients by misuse of NMCE platform–Reassessment notice is held to be justified. [S.143(1), Art.226]

S. 144C : Reference to dispute resolution panel – E-proceedings facility – Manual mode- Period of limitation- Receipt of a draft assessment order in manual mode had to be seen as date of draft assessment order- Judgement is peculiar factual circumstances, hence not to be cited as a precedent in subsequent cases. [S. 92C, Art.226]

S. 143(3) : Assessment–Notice–Dead person-Order is non est in law – Notice was quashed. [S.143(2), 292B, Art.226]

S. 143(3) : Assessment–Natural justice- Opportunity of hearing – Agricultural income– Capital gains-Notice given-Reply furnished by the assessment- Assessment order passed denying the exemption without giving personal hearing–Order is not bad in law–No prejudice caused to the assessee through denial of personal hearing. [S. 2(IA), 10(1), 143(2), Art. 226]

S. 143(3) : Assessment–Remand–Order giving effect to the order of Tribunal-Enhancement-Capital gains–business income-Client code modification-The AO is not entitle to expand the scope of the assessment proceedings beyond the issue remanded- Order of the AO is set aside. [S. 28(i), 45,254(1), Art. 226]

S. 115JB : Book profit-Forward foreign exchange -Not contingent in nature–Binding obligation on date of contract against the assessee-Deletion of addition by the Tribunal is affirmed– Question which was not raised before the Tribunal cannot be raised first time before Court during the Course of oral arguments. [S. 37 (1), 260A]

S. 92C : Transfer pricing–Arm’s length price–Comparable-Employee cost filter-Company which out sourced its work cannot be accepted as comparable–ITES services–Cannot be excluded merely because it did not make profit relevant assessment year.

S. 80HHC : Export business-Entitle to deduction on gross total income without reducing it by the deduction allowed u/s. 80IB of the Act. [S. 80IA (9), 80IB]

S. 69C : Unexplained expenditure–Bogus purchases– Accommodation entries-Restricting the disallowances at 5% of alleged bogus purchases is held to be justified–Entire purchases cannot be disallowed. [S. 37(1)n, 144]