S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Change of opinion-Transaction in shares-Live link between belief and material in possession is not established-Reopening on suspicion is impermissible. [S. 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Eligible assessee-Draft assessment order-Failing to communicate to Assessing Officer Final assessment order is passed during pendency of objections-Order set aside and Assessing Officer is directed to pass fresh order in accordance with directions of Dispute Resolution Panel. [S. 143(3) 144B, 144C(2), 144C(3), 144C(4), Art.226]

S. 144C : Reference to dispute resolution panel-Eligible Assessee-Draft assessment order-Final assessment order passed while assessee’s objections against draft assessment order sub-judice before Dispute Resolution Panel-Assessment order, notices of demand and penalty set aside-Assessing Officer is directed to pass fresh order in accordance with directions from Dispute Resolution Panel. [S. 144, 144B, 144C(2)(b)(ii), 144C(3), 156, 270A, 274, Art. 226]

S. 144B : Faceless Assessment-Approval of Resolution Plan under Corporate Insolvency Resolution process-Subsequent notice Under Section 144B is not valid.[Insolvency And Bankruptcy Code, 2016, S. 31(1), Art. 226]

S. 143(3): Assessment-Order of assessment without providing assessee opportunity to be heard-Not valid.[Art. 226]

S. 132 : Search and seizure-Reason to believe must exist at time of issue of warrant of authorisation for search-Department must give specific details to justify search-Merely on basis of warrant of authorisation-Search and seizure invalid-Survey-Notice of survey issued pursuant to search is not valid-Interpretation Of Taxing Statutes-Strict constructions.[S. 131(IA), Art. 226]

S. 119 : Central Board of Direct Taxes-Circular-Delay in filing return-Condonation of delay-National Company Law Tribunal-Revised books of account-Genuine hardship-Power vested in Authority to be judicially exercised-The assessee could file before the jurisdictional Assessing Officer physical returns of income based on books of account revised under section 130(2) of the 2013 Act, as taken on record by the National Company Law Tribunal for the assessment years 2015-16 to 2020-21 within the time stipulated in this order. [S. 119(2)(b). 139(4), Companies Act, 2013, S. 130, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Intra-Group services-Application of Arm’s Length Price adjustment resulting in reduction of income chargeable to tax-Transfer pricing provisions cannot be applied.[S.92(1), 92(3), 92B, 260A]

S. 80-O : Royalties-Foreign enterprises-Royalty or fees received from foreign entity-Mere claim of sending newspaper cuttings does not amount to proof of sharing commercial expertise-No evidence for provision of information to foreign entity-Deduction rightly rejected by Tribunal.[S. 260A]

S. 43B : Deductions on actual payment-Electricity Duty on sale of power payable to Government adjusted against sums due to assessee from Government-Entitled to deduction-Produce Certificate from Chartered Accountant to establish adjustment made within time as claimed. [Art. 136]