S. 153C : Assessment-Income of any other person–Search- Recording of satisfaction is mandatory even if the Assessing Officer of the person in respect of whom the search was conducted and the other person was one and the same-Additions were deleted. [S. 132]

S. 153A : Assessment–Search-Assessment completed on date of search–Additional ground raised before Tribunal -No incriminating material found-No jurisdiction to frame the assessment. [S. 69C, 254(1)]

S. 147 : Reassessment–With in four years-Non application of mind- Recording of incorrect figures-Merely repeating investigation report–Reassessment is held to be invalid. [S. 148]

S. 147 : Reassessment–With in four years-Provision for doubtful debt–Unabsorbed depreciation- Reassessment is held to be valid [S. 32(2), 148 ]

S. 147 : Reassessment–Capital asset -Agricultural land-Location of land from local limits of Chennai Municipal Corporation was relevant to decide as to whether said land was an agricultural land within meaning of S. 2(14)(iii) and distance of land from Chennai Metropolitan area was not relevant- Reassessment is held to be bad in law.[S. 2(14)(iii), 148]

S. 145 : Method of accounting–Valuation of closing stock at nil- Consistent method of accounting–Deletion of addition by CIT(A) is held to be justified.

S. 115JB : Book profit–Housing project-Development of housing project units which were neither units in SEZ nor developer of SEZ- Not entitle to exempt from MAT.[S. 80IB(10)]

S. 115JA : Book profit–Foreign Banking company-Maintaining its accounts under Banking Regulation Act, 1949-Provision is not applicable -DTAA- India -UK. [Art. 7, Banking Regulation Act, 1949, Companies Act, 1956]

S. 115BBC : Anonymous donations–Names and address along with other particulars of donors who have given donation was furnished- Donation cannot be assessed as anonymous donation.

S. 92C : Transfer pricing–Arm’s length price-Weighted average– Exporting carpets to foreign associated enterprise as well as unrelated parties-Variation of rates–AO is directed to apply weighted average of all transactions -Sale proceeds to be realised from the associated enterprises were in foreign currency, instead of applying the prime lending rate as the arm’s length price, interest at the LIBOR shall be considered as the arm’s length interest – The effect of the exchange gain or loss had to be given in computing of arm’s length price being the part of sale proceeds as well as comparable price. [S. 92CA]