S. 143(1) : Assessment-Intimation-Revised return filed within limitation period-Scrutiny assessment ignoring revised return not valid-Processing of return under Section 143(1)(A) not an assessment order-Penalty Not Imposable [S. 143(1)(a), 143(IA) 143(3), 260A, 271 (1)(c)]

S. 92CA : Transfer pricing Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Assessing Officer cannot make Transfer pricing adjustment which is not considered by Transfer Pricing Officer. [S.92C, 144C, Art. 226]

S. 92CA : Transfer pricing Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Parent company of subsidiary-Not controlling and determining quantity of production-Sales to associated enterprises under individual contracts-Not payment of royalty-Not profit-shifting mechanism even if royalty embedded in sale price-Contract manufacturer-Royalty payment by subsidiary to its parent company abroad-Comparable to those in open market-Transfer pricing adjustment of royalty is not justified-No substantial question of law. [S.92C, 260A, R.10A, 10E]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Order in conformity with directions of Supreme Court guidelines-No substantial question of law.[S. 260A]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Manufacture or production of GITTI from sand stone blocks-Amounts to manufacture or production.[S.80IB, 260A]

S. 68 : Cash credits-Sundry credits and unsecured Loans-Responding to notice under Section 133(6) and confirming transactions through banks in their statements under Section 131-Order of Tribunal is affirmed-No substantial question of law. [S. 131, 133(6), 260A]

S. 68 : Cash credits-Long-term capital gains-Penny stock-Sunrise Asian Ltd-Exemption-Information from Investigation Wing-Presumptions is not corroborated by evidence-Order of Tribunal deleting the addition is affirmed.[S. 10(38), 45, 115BBE, 133(6), 260A]

S. 37(1) : Business expenditure-Bogus expenses-Construction business-Payments made to Sub-contractors-TDS is deducted-Order of Tribunal confirming the disallowance is affirmed-No substantial question of law. [S.260A]

S. 37(1) : Business expenditure-Provision for contingent liabilities-Order of Tribunal is affirmed-No substantial question of law.[S. 260A]

S. 37(1) : Business expenditure-Bogus expenses-Construction business-Payments made to Sub-contractors-TDS is deducted-Order of Tribunal confirming the disallowance is affirmed-No substantial question of law-SLP of assessee is rejected. [Art. 136]