S. 147 : Reassessment-After the expiry of four years-Capital gains-Authority for Advance ruling-Ruling would apply and be binding only on applicant-Subsequent ruling on other assessee cannot be the basis for reopening of the assessment-DTAA-India-UAE [S. 9(1)(i), 148, 245R, 245S, Art. 4, 10, 11. 13(3)]

S. 144C : Reference to dispute resolution panel-Time limit-Direction of DRP-Uploading on ITBA portal on 17-6-2022-Final assessment order was passed on 25-3-2023-Order is barred by limitation. [S.92CA, 144B, 144C(13), Art. 226]

S. 144B : Faceless Assessment-Pendency of appeal before CIT(A)-Direction is issued to the appellate authority to pass an appropriate order on the merits and in accordance with law, after affording an opportunity of personal hearing to the assessee within a period of twelve weeks. [S. 144B(1) (xii), 246A, Art. 226]

S. 144 : Best judgment assessment-Reassessment-Schedule Tribes-Investment in mutual funds-Return not filed-Not responded to the notice-Alternative remedy-Writ petition is dismissed.[S. 10(26), 139(1),139(4C), 147, 148. Art. 226]

S. 143(3): Assessment-Order passed without giving assessee an adequate of opportunity of being heard-Order is not valid-The Assessing Officer is directed to pass an appropriate order as per law. [Art.226]

S. 143(3) : Assessment-Unexplained expenditure-Purchase of bullion/jewellery-Question of fact-Writ petition is dismissed.[S.69C, 144B,Central Goods and Service Tax Rules, 2017, Notification No. 12 of 2018 (Central Tax (2018) GSTR (St)1, Art. 226]

S. 143(3) : Assessment-Limited scrutiny assessment-Assessing Officer had initially issued notice under section 143(2) for a limited scrutiny on three aspects-Assessing Officer could not have expanded scope of scrutiny without prior to obtaining approval for a complete scrutiny from appropriate authority. [S.119, 143(2), 260A]

S. 119 : Central Board of Direct Taxes-Circular-Defective return-Genuine hardship-Lock down period-Delay in filing application for rectification of error committed in return of income is condoned. [S. 44ADA, 119(2)(b),139(5), 139(9), 154, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-
International transaction-Foreign exchange gains/loss-Operating income/loss is proper-Comparable-Exclusion of comparable is proper. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Gains arising due to fluctuation in rate of foreign exchange-Income-safe harbour