S. 147 : Reassessment-Non-existent reason-Indexation cost was raised in the recorded reason–Court cannot allow the AO to improve upon the reasons in order to support the notice of reassessment- Execution of sale deed by virtue of the judgement of the High Court would relate back to the original agreement to sale, and the assessee is entitle to claim the benefit of cost of indexation from the said date. [S. 2(47), 45, 48, 148]

S. 147 : Reassessment-Identical issue is pending before CIT (A) for the AY. 2015 -16- Writ is held to be not maintainable. [S. 80G,115BBC, 148 Art. 226]

S. 147 : Reassessment-Report of investigation Wing- Accommodation entries–Assessment u/s.143(1)-Notice for reassessment is valid. [S. 143(1), 148]

S. 143(3) : Assessment-Jurisdiction-When the Commissioner requires the Assessing Officer to carry out inquiries with respect to specific issues, the jurisdiction of the Assessing Officer to pass fresh order must be confined to such issues only. [S. 263]

S. 142(2A) : Inquiry before assessment–Special audit–Audit report was provided to the assessee-AO shall allow the assessee to raise the objections to the said report and decide according to law – All issues are kept open. [S. 143(3)]

S. 92C : Transfer pricing–Release of money in favour of Associated Enterprise with a specific purpose of acquisition of distributorship of the films from Citi Gate Trade FZE is not a case of either financing or lending or advancing of any moneys- Not International Transaction did not result in to diversion of income of the assessee to the Associated Enterprise. [S. 92, 92B, 92D, 92E]

S. 80IB : Industrial undertaking-Business of manufacturing Menthol-Profit from hedging–Hedging activity of Mentha Oil has direct nexus with the manufacturing activity and profit derived from hedging is eligible for deduction.

S. 80DD : Medical treatment of dependent–Disability–Observations-Jeevan Aadhar-Amount of annuity under the policy is to be released only after the death of the person assured -Purpose is to secure the future of the person suffering from disability , after the death of the parent / guardian–Provision is valid in law -Considering the several difficult situations where the handicapped person may need the payment on annuity or lumpsum basis even during the life time of their parents / guardians, it is for the legislature to take care of theses aspects and to provide suitable provision by making necessary amendments in S.80DD. [Art. 14]

S. 43D : Public financial institutions-Co-Operative Bank–Non performing assets (NPA)-Accrual of interest income- Provision is applicable to Co -Operative Societies–Amount transferred to overdue interest Reserve (OIR) by debiting the interest received in profit and loss account, cannot be assessed on accrual basis. [S. 145]

S. 37(1) : Business expenditure-Amortized premium on investment in govt .Securities held under category “Held to Maturity”) (HTM) is held to be revenue expenditure.