S. 151 : Reassessment-Sanction for issue of notice–Notice u/s 148 issued beyond 3-year period-As per amended Section 151 (post 01.04.2021), approval from PCCIT/CCIT was required, but approval was taken from PCIT-Reassessment proceedings quashed. [S. 147, 148]

S. 151 : Reassessment-Sanction for issue of notice-Approval is granted in mechanical manner-Reassessment is quashed Communication of assessment order-Assessment orders and demand notices issued u/s. 156, without a Document Identification Number (DIN) are unsustainable in law and can be considered invalid. [S. 119, 147 148, 156]

S. 147 : Reassessment-CIT(A) partly allowed the claim against losses-reopening of assessment on same issue-CIT(A) allowed the reopening-Held, reopening not valid as no fresh material on record. [S. 148]

S. 147 : Reassessment-Best judgment assessment-Unexplained money-Entire cash deposit cannot be treated as income-Income of the assessee is estimated at 10 per cent of cash credit and other credit. [S.69A 148, 249(3)]

S. 144C : Reference to dispute resolution panel–Assessee did not file ITR-Assessment reopened u/s 147-Capital gain not declared-limitation-Assessment order barred by limitation as extended time limit u/s 153 not applicable. [S. 2(14)(iii), 144C(13), 147, 148, 153 (2), 153(4)]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Transactions between head office (HO) and Project Office (PO) in India-Transactions between a foreign enterprise and its PE in India qualify as international transactions under section 92B, even if both are non-residents subject to ALP adjustment-The matter is directed to be placed before the Division Bench to give effect to the direction-DTAA-India-China [S.92 Art. 7(2),9]

S. 90 :Double taxation relief-Mauritius company-Indian company shares acquired before 01-04-2017-Sale claimed as exempt using Article 13(4) of the DTAA-No capital gains as TRC was given and grandfathering of treaty.-DTAA-India-Mauritius [S.90, Art. 13(4)]

S. 90: Double Taxability Relief-Foreign Tax Credit (FTC)-Denial due to delayed filing of Form No. 67-Directed to allow the claim. DTAA-India-Netherlands.[Form No.67, Art. 23]

S. 90: Double taxation relief-Foreign business income-Tax paid in Nepal-Delay in filing Form No. 67-Assessee would be entitled to FTC. DTAA-India-Nepal [Form No 67]

S. 90 : Double taxation relief-Foreign tax credit-Form No. 67 not filed within due date of filing return under section 139(1) but filed before processing of return by CPC-Directory and not mandatory-Foreign tax credit cannot be denied. [S. 139(1) Form No 67]