S. 144C : Reference to dispute resolution panel-Assessing Officer passed final assessment order in case of assessee on 21-11-2017 after one month from end of month in which he received directions of Dispute Resolution Panel i.e., 18-9-2017-Order is time barred hence quashed and set aside. [S.92CA,144C(13)]

S. 144C : Reference to dispute resolution panel-Limitation period-Date of uploading DRP order on ITBA portal was 27-4-2022-Assessment completed on 30-6-2022 is time barred as null and void. [S. 143(3), 144C((13), Information Technology Act, 2000, S.13]

S. 143(3) : Assessment-Revision order is quashed by Tribunal-Assessment order became infructuous. [S. 143(3), 254(1)]

S. 143(2) : Assessment-Notice-Cash credits-Reassessment-Failure to issue statutory notice-Order is bad in law-Not curable defects.[S.68, 143(3) 147, 148, 292BB]

S. 143(1) : Assessment-Intimation-Penalty-Tax auditor had categorized amount in question as penalty-Prima facie disallowable under section 143(1)(a)(iv)-AO is not required to pass a speaking order for said adjustment made in strict terms-Matter remanded the matter to the file of CIT(A) to deciding a fresh on merit. [S.37(1), 143(1)(a)(iv)]

S. 143(1) : Assessment-Intimation-Appealable before Commissioner (Appeals)-Additions for ICDS and Any sum received from employees-Scrutiny assessment maintaining disallowance made under Section 143(1)-Challenged before CIT(A) against the order under section 143(3)-Failure to adjudicate additions/disallowance made under S.143(1)-Order of CIT(A) is affirmed-For challenging an intimation the assessee should file an appeal before the First Appellate Authority under S. 246A.[S.36(1)(va), 143(3),246A]

S. 120 : Jurisdiction of income-tax authorities-No order is passed transferring the jurisdiction-Order is set aside.[S.2(7A), 120(4)(b) 127, 144C(13)]

S. 90 :Double taxation relief-Rate applicable to domestic companies-Non-discrimination clause-Higher rate of tax prescribed for foreign company is not to be regarded as violation of non-discriminatory clause, i.e., article 26 of DTAA between India-France. [Art. 26]

S. 90 : Double taxation relief-Tax credit-Tax paid in Kenia-Rule 128 was inserted by Income-tax (18th Amendment) Rules, 2016 and was made applicable with effect from 1-4-2017,-Could not be made applicable for relevant assessment years-Claim is allowed-DTAA-India-Kenia [S.91, R. 128, Form No 67, Art. 25]

S. 90 :Double taxation relief-Rule 128 is directory in nature and not mandatory and, thus, foreign tax credit could not be denied to assessee merely on ground that Form No. 67 was filed belatedly.[Rule 128, Form No 67]