S. 144C : Reference to dispute resolution panel -Order passed by DRP must contain discussion of facts and independent findings on those facts by DRP; mere extraction of rival contentions will not satisfy requirement of consideration-Matter remanded. [S. 92C]

S. 144C : Reference to dispute resolution panel–Remand- Direction by the ITAT to AO/TPO to undertake a fresh exercise of determination of Arm’s length price -Failure to pass draft assessment order would violative of S.144C(1) hence bad in law -Not curable defects. [S. 92C, 153(2A), 254(1), 292B]

S. 139 : Return-Processing of return-Refund-Return filed by assessee had been forwarded to CPC by Assessing Officer-In such circumstances, CPC should take a decision as regards computation in 4 weeks-Not the Assessing Officer. [S. 237]

S. 132 : Search and seizure-Illegal search-Karta of HUF had initiated litigation against alleged illegal search action of department on HUF at relevant time, a member of HUF individually could not restart same litigation long many years after cause of action had arisen. [S. 158BC, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Adjustment of interest-Foreign subsidiary-Corporate guarantee-Loan to Associated Enterprises- Delay in realizing sale proceeds from Associated Enterprises – Adjustment should be made at average LIBOR rate existing at that time, i.e., at 0.79 per cent, instead of LIBOR +2 per cent. [S. 92B]

S. 69C : Un explained expenditure-Cash payments-Slips found during search-Since there was no material to substantiate assumption that slips denoted amounts outside cash book of assessee, addition was held to be not justified. [S. 132]

S. 69 : Undisclosed investment -Deletion of addition by the Tribunal is held to be appreciation of evidence -No substantial question of law. [S. 260A ]

S. 69 : Unexplained investments–Cash payments-diary seized from sister concern -Since no other evidence was recorded during search nor concerned person against whose name entry in diary appeared was examined, said addition was to be deleted. [S. 132(4)]

S. 68 : Cash credits- Bank details and other particulars were furnished–Merely on the basis of report addition cannot be made -Deletion of addition is held to be justified. [S. 260A]

S. 45 : Capital gains-Business income-Sale of shares-Only 10 scripts-Assessable as capital gains. [S. 28(i)]