S. 144C : Reference to dispute resolution panel–Draft assessment order-Assessee is a LLP in Germany-TPO had not proposed any variation– Assessee was not a foreign company assessee is not eligible to draft AO order-Draft assessment order and final order passed by AO held void ab initio-DTAA-India–Germany. [S. 144C(15) (b), Art. 12]

S. 143(3) : Assessment–Books of account–TDS return-Difference in income as per 26AS and books of accounts–No additions can be warranted. [S.28(i), Form, 26AS]

S. 143(3) : Assessment-Bogus Purchase–In absence of any corroborative evidence, purchases made by assessee from hawala dealers cannot be treated as bogus purchases and be not added to total income. [S. 69, 148]

S. 132(4) : Search and seizure-Statement on oath–surrendered income– Expenses computed–irregularity in accounts–addition is not justified.

S. 132 : Search and seizure–No search warrant–Search declared as invalid –Block assessment is also invalid.[S. 158BC, 158BD]

S. 92CA : Reference to transfer pricing officer–Arm’s length price- Advertisement and publicity expenses-Additional grounds-ALP disputed for the first time before the Tribunal-Additional ground is rejected as it virtually result in re-opening of the assessment. [S. 92C, 254(1)]

S. 92C : Transfer pricing-Asssessee paid consultancy fees and other reimbursement to Associated Enterprise–AO asked for details regarding such international transaction–assessee filed details however the TPO was not convinced and made addition–DRP confirmed as no new material was brought on record–ITAT remanded the matter back to AO for de-novo consideration.[S. 254(1)]

S. 80IA : Industrial Undertaking-Industrial undertakings–Infrastructure development-Operating and maintenance of airport-Agreement between airports authority and the assessee-Entitled to deduction. [S. 80IA(4)(i)(c)].

S. 69 : Unexplained investments–Cash transactions in bank accounts- Source of cash deposits–failed to explain source–Addition is held to be justified. [S. 131(1)]

S. 68 : Cash credits-Addition on basis of statement of person who retracted it later-No opportunity of cross-examination given to assessee-Neither Assessing Officer nor Investigating Authorities bringing on record any incriminating documents to suggest assessee holding unaccounted income brought back as loans and advances-No unexplained credits in hands of assessee.