S. 153C : Assessment-Income of any other person-Search and Seizure—Issue of notice is mandatory-The amendment in S.153C by the Finance Act, 2017, with effect from April 1, 2017 to the effect that the block period for the person in respect of whom the search was conducted as well as the “other person” would be the same six assessment years immediately preceding the year of search was prospective in nature-Order is held to be bad in law. [S.132, 153B(1)(b)]

S. 153C : Assessment-Income of any other person-Search and seizure—Satisfaction note is not available-Assessment is held to be bad in law. [S. 153A]

S. 147 : Reassessment-Deposit in bank–Merely on the basis of deposit made in bank, reassessment is not valid when there is contradiction between statement recorded and information of recording reasons. [S. 148]

S. 143(3) : Assessment–Assessment of amalgamating company-Notices were issued prior to the amalgamation with another company–Assessment proceedings cannot be held to be invalid. [S.142(1), 143(2)]

S. 92C : Transfer pricing–Arm’s Length price-CUP method-TNMM- International transactions combined by assessee for showing them at ALP cannot be aggregated where assessee fails to show any inextricable link between these transactions as one not surviving without the other and there is no package deal and the international transaction in question is separately valued and there is nothing to show an understanding that the pricing was dependent upon the assessee accepting all of them together- Matter remanded.

S. 92C : Transfer pricing–Arm’s length price–CUP method- Interest free loan to subsidiary–Shares were allotted– Adjustment is held to be not justified.

S. 92C : Transfer pricing–Inter group services-Payments in accordance with the written agreements-Adjustment is held to be not justified. [S. 92CA]

S. 80P : Co-Operative society—Investments in other co-operative societies – AO is directed to grant exemption if institutions where the assessee has made investments is found to be co-operative society. [S. 80P(2)(d)]

S. 68 : Cash credits—Deposit in bank account-Not maintaining books of account–Presumptive taxation–Return was accepted-Addition as cash credit is held to be not valid. [S. 44AF]

S. 50C : Capital gains-Full value of consideration-Stamp valuation Property not freehold property but occupied by tenants and court cases to get premises vacated pending—Kanpur Development Authority issuing letters to assessee proposing to take over certain portion of his property in connection with road widening— Addition on account of difference in stamp duty and sale deed is not justified. [S. 45]