S. 147 : Reassessment – After the expiry of four years – Full and true disclosure – Merger of AO’s order with order of CIT(A) – AO having rejected the claim of deduction under S. 80-IA(4)and the CIT(A) allowing the claim in its entirety – AO cannot reopen this very claim for possible disallowance of part thereof

S. 142(2A) : Inquiry before assessment–Special audit–Limitation- Manipulation in dates by Department proved-Notices of SLP against order of High Court dismissing Writ petition against special audit under S.. 142(2A) issued and directions of High Court order stayed.

S. 115JA : Book profit – Adjustment of provision for bad and doubtful debts [under Clause (c) of S. 115JA(1)] is permitted only when such provision is made for an unascertained liability.

S. 115J : Book profit – Explanation (iv) to s. 115J cannot be read or enlarged in the manner so as to allow an impermissible act of reopening of the accounts

S. 92C : Transfer pricing – Arms’ length price – Selection of comparables -Finding of fact by Tribunal that (i) the activities of the assessee and comparables are functionally different(ii) the extraordinary events such as merger/amalgamation would have an impact/effect on the profitability of comparable (iii) merely because both assessee and the comparable provide ITES services they do not become comparable, cannot be interfered, more particularly in the absence of the same being shown to be perverse-No question of law. [S. 260A]

S. 80P : Co-operative societies -Providing credit facilities to members – Interest earned by the society in investing in the banks – Activity of carrying on business in the banking or providing credit facilities to its members is eligible for deduction- Matter remanded to Assessing Officer.[ S. 80P(2)(a)(i)]

S. 80G : Donation -Recognition of institution -Without finding of fact that the funds utilised for private purposes or charitable purposes – declining approval is not justified .[ S.80G(5)(vi)]

S. 69C : Unexplained expenditure – Unexplained expenditure on production is deleted as the relevant records produced by the assessee were found to be in order without any serious errors -Regarding packing material, it has been pointed out that the cost of packing material with regard to the assessee-unit as well as two other units differs, hence, addition made by AO is justified. [S. 80IB]

S. 37(1) : Business expenditure –Capital or revenue-Assessee did not purchase and acquire title in the trademark or retain any rights in the mark – Lump-sum payment was for obtaining an advantage in carrying on its business as it merely facilitated the assessee’s business in India and hence of revenue nature.

S. 12AA : Procedure for registration –Trust or institution –Genuineness of trust and its activities are not doubted – Registration cannot be refused. [ S.2(15), 11]