S.147: Reassessment-After the expiry of four years-Bogus transactions-Change of opinion-Borrowed satisfaction-Lack of application of mind-Reopening invalid. [S. 68, 148, 151]

S. 145: Method of accounting-Rejection of books of account-Estimation of profits-Addition was deleted-Delay in appeal –Delay of 880 days-Delay was condoned. [S. 144, 145(3),253, Rule 46A]

S. 145: Method of accounting-Rejection of Books-Estimation of Profit-Form 26AS Difference-Loan Waiver-One-time settlement. Additions were deleted. [S. 145(3), 28(iv), 41(1), 145(3)]

S. 144C: Reference to dispute resolution panel-Limitation-Assessment-Transfer Pricing –CBDT Notifications-Assessment was time-barred-Invalid. [S. 143(3), 144B, 144C(3), 153(4)]

S. 143(3): Assessment-Suppression of Sales-Consignment sales are treated as unaccounted sales-Only gross profit and investment in purchases are taxable, not the entire sale proceeds. [S. 69]

S. 143(2): Assessment-Notice-Jurisdiction-Notice by Assessing Officer-Pecuniary jurisdiction-Non-issue of mandatory notice-The assessment was held to be void ab initio and was quashed. (S. 143(3)]

S.142(2A): Inquiry before assessment-Special audit-Satisfaction of Assessing Officer-Extension of time-Special audit order is void where satisfaction is not independently recorded by the Assessing Officer and statutory procedure under sections 142(2A) and 142(2C) is not followed.[S. 143(3), 153]

S. 120: Jurisdiction of income-tax authorities-Assessment-Jurisdiction-Additional Commissioner acting as Assessing Officer-Absence of authorisation under sections 120(4)(b) and 127-Assessment without jurisdiction liable to be quashed-Additional legal grounds challenging jurisdiction admissible before Tribunal.
[S. 2(7A), 120(4)(b), 124(3), 127, 143(3), 144C, 254(1)]

S. 92C: Transfer Pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Functionally dissimilar companies are to be excluded while determining the arm’s length price. [S. 92CA, 92F]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Export Commission-Adjustment was deleted-Royalty and technical know-how-Revenue expenditure-Expenditure incurred on glow signboards, signage, sales tools and dealer fixtures was also held to be revenue expenditure-Education cess-Not allowable as deduction-Dividend Distribution Tax-Matter remanded to the file of Assessing Officer. [S.37(1), 40(a)(ii)]