S. 147 : Reassessment-Duty Draw Back and other such incentives were not profits derived from eligible business and accordingly exemption u/s.10BA could not be allowed in respect of Duty Draw Back and other export incentives—Matter was remanded back to AO to decide same afresh in accordance with law, however, leaving it open for both parties to raise all contentions before AO—Matter remanded. [S. 10BA, 148]

S. 147 : Reassessment–Disallowance of 20% expenditure–Bogus dealers- Reassessment is held to be valid. [S. 40A(3), 148]

S. 147 : Reassessment-Mere non quoting of reasons formed by AO in notice would not vitiate entire proceedings- communication of all reasons for reopening of assessment at time of issuance of notice was not necessary—When notice was issued within timeline provided by virtue of s. 149(1)(b), challenge raised by assessee on point of limitation was not sustainable—Since assessee was holding high position of Union Minister and since, transaction were believed to be multi folded, which warranted further investigation, issuance of notices on multiple choice could not be faulted—Writ petition was dismissed. [S.148/ 149(1)(b)]

S. 132(4) : Search & seizure-Retraction of statement after eight months -Addition on the basis of statement is held to be justified- Appeal of revenue is allowed. [S. 131, 132]

S. 127 : Power to transfer cases-Transfer of case from Kolhapur to Mumbai – “Centralisation Committee” which took decision for transfer of jurisdiction, is not authority envisaged u/s 127(2)- Absence of dissenting note” from officer of equal rank who has to agree to proposed transfer would not constitute agreement, envisaged u/s 123(2)(a)–Transfer order was quashed. [S. 123(2)(a), 127(2)]

S. 127 : Power to transfer cases–Co–ordinated investigation- Transfer of case from Kolhapur to Mumbai –Justifying the transfer of case was not furnished – Notice to transfer the case is quashed.

S. 92C : Transfer pricing-Comparable—Functionally different activities cannot be taken for determination of Arm’s length price.

S. 92C : Transfer pricing–Comparable–Functionally indifferent companies cannot be selected as comparables. [S.260A ]

S. 80IB : Industrial undertakings–Contract for manufacturing of product-Manufacturing activity undertaken by that other entity for and on behalf of Assessee was not under its direct supervision and control –Not entitle to deduction.

S. 80HHE : Export business-Computer software-Claim was not made when the return was filed-Claim was made when the amount was received–Entitle to deduction.