S. 147 : Reassessment-Information received from Investigation wing– Accommodation entries-Share capital-Failure to examine in original assessment proceedings–Reassessment notice is held to be valid. The assessee was permitted to raise its objections in the light of the documents provided by the respondent in court within seven days. The Assessing Officer shall decide the objections that may be raised within two weeks.. [S.68, 148, Art. 226]

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]