S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Bad debt-Specific question was raised in the course of assessment proceedings-Change of opinion-Reassessment notice and order disposing the objection is quashed and set aside.[S.36(1)(vii), 142(1), 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Appellate Tribunal-Matter is remanded. [S. 92C, 143(3), 254(1), Art. 226]

S. 144C : Reference to dispute resolution panel-Transfer pricing-Computation of arm’s length price-Failure to pass draft assessment order-Assessment order is null and void. [S.92CA(2),92CA(3),]

S. 144B : Faceless Assessment-Draft assessment order is not passed-Violation of principle of natural justice-Order is quashed and set aside. [Art. 226]

S. 119 : Central Board of Direct Taxes-Refund-Condonation of delay-Delay in filing of return-PCIT has no power to consider the merits of the refund application and what is required to be considered is the merits of the application for condonation of delay only-Matter is remitted back for reconsideration. [S. 119(2(b), 139, 237, 240, Art. 226]

S. 115BBE : Tax on specified income-Determination of tax in certain cases-Reassessment-Limitation-Alternative remedy-Act provides complete machinery for assessment/reassessment of tax and the assessee is not permitted to abandon that machinery to invoke jurisdiction of the High Court under Art. 226 of the Constitution-S. 115BBE cannot be held unconstitutional on the ground that there an apprehension of misuse of the said provision. [S. 68, 148, 148A, 149, Art. 14, 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Net Margin Method-Advertisement, marketing and promotion expenses-Comparison-Application of BLT tool was wrong-No substantial question of law.[S. 260A]

S. 80JJAA : Employment of new workmen-Period of 300 days can be taken in to consideration both in the previous and succeeding years-It is not required that workmen work for 300 days in previous year relevant to assessment year-Appeal of assessee is allowed.[S. 260A]

S. 68 : Cash credits-Agriculturist-Cash deposit in foreign bank in Geneva-Bank account belonged to his nephew residing in U.K-Deletion of addition is affirmed.[S. 69, 260A]

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Purchases of amount exceeding Rs. 20, 000, on a single day-Failure to produce bills-Disallowance made by Assessing Officer of 20 per cent of cash payments is affirmed. [R. 6DD, 260A]