S.147: Reassessment — Client code modification -Information from investigation wing regarding evasion of tax by assessee —Notice is held to be valid .[ S. 133A,148 ]

S.144C : Reference to dispute resolution panel – Transfer Pricing Officer – Draft assessment order- Reference to TPO – Failure to comply with statutory requirement under S.144C, defects cannot be cured by issuing corrigendum – Order of assessment is held to be void . [S.92CA, 143(3), 292B ]

S. 92C : Transfer pricing – Arm’s length price -Difference between Knowledge process outsourcing and business process outsourcing- The conclusion of the Tribunal was justified and on facts the Tribunal was correct in excluding the comparable companies- Explanation to S. 92B By Finance Act, 2012 — Delay in realisation of trade debt — Transfer pricing provisions is applicable [ S.92B ]

S. 92A : Transfer pricing – Associated enterprises -Supplier of assessee is not manufacturer — Assessee and supplier Partnership is not controlled by individuals — Neither of Firms holding 10 Per Cent. interest in each other- Not associated enterprises .[ S.92C ]

S. 80HH :Newly established industrial undertakings – Back ward areas –Processing of cashew nuts in own factory and Industrial undertaking of sister concerns in backward areas —Entitle to deduction .

S.68:Cash credits — Share capital — Genuineness of investors in shares were not satisfactorily explained — Order of Tribunal is affirmed .[ S.260A ]

S.68 : Cash credits – Interest- Deletion of addition is held to be justified – Provision for forward contract -Question of fact [ S. 37(1) ,260A.]

S. 68 : Cash credits -Loan – Produced details like copies of permanent account number cards, returns, balance-sheets with all the annexure and bank accounts before the Assessing Officer, that two of the creditors not only appeared before the Assessing Officer, but had also admitted giving loan and that there was nothing suspicious or doubtful in the version of those persons -Deletion of addition was held to be justified – Transportation charges – tax deducted at source, payments through account payee cheques, proper addresses and confirmation of account with permanent account numbers and gross receipts from the Municipal Corporation of Greater Mumbai on account of supply of vehicles in the financial year- Merely because the parties were not physically present before the Assessing Officer, such an addition could not have been made – Deletion of addition was held to be justified . [ S.133(6), 260A ]

S. 45 : Capital gains – Dissolution of firm -Land was introduced as capital in one of the partner –Revaluation – Land was sold before dissolution- Capital gains is assessable in the hands of firm . [ S.45(4) ]

S. 41(1) : Profits chargeable to tax – Remission or cessation of trading liability -Amounts remaining unrecoverable as creditors untraceable cannot be the ground to conclude that there was cessation of liability .