S. 153C : Assessment- Income of any other person- Search- Incriminating documents specifically identifying assessee-Addition upheld- Cash payments evidenced by seized documents-Failure to rebut evidence-Addition sustained- Satisfaction under amended provision-Proceedings valid.[S 69A, 69C,. 132, 133A, 153A]

S. 147: Reassessment- Income from other sources-Interest reflected in Form 26AS-No actual receipt-Addition deleted- Reassessment was invalid.[S. 56, 148, Form No. 26AS]

S. 144: Best judgment assessment- Rejection of books-Estimation of income-Addition restricted on basis of earlier accepted profit rate. [S. 44AB, 145(3)]

S.143(3): Assessment- Limited scrutiny-Enquiry into assets and liabilities arising from information furnished during assessment-Within scope of scrutiny.[S.2(13), 22, 23, 28(i), 44AD]

S 143(3): Assessment-Ex parte order-Principles of natural justice-One more opportunity to assessee-Matter remanded.[S. 250, 254(1)]

S. 133A: Power of survey-Statement recorded during survey-No evidentiary value-Addition based solely on survey statement and third-party documents deleted.[S.292C]

S. 115JB: Company- Book profit-Corporate Social Responsibility expenditure-Provision made in accordance with Companies Act-Not liable to be added back while computing book profit.[S. 37(1), 115JB, Expln. 1]

S. 92C: Transfer pricing-Arm’s length price- Avoidance of tax-International transaction- Advertisement, Marketing and Promotion (AMP) expenditure-No international transaction established-Transfer pricing adjustment deleted- Intra-group services-Earlier year’s order followed-Matter remanded to Transfer Pricing Officer- Assessment-Fresh claim made during assessment proceedings-No revised return filed-Claim raised before appellate authorities maintainable-Matter remanded.[S.92CA, 143(3)]

S.92BA: Transfer pricing-Specified domestic transaction- Arm’s length price-Avoidance of tax Transfer Pricing-“Arrangement” between eligible and non-eligible units is condition precedent-Additional evidence admitted-Matter remanded.[S. 80-IA (10) 80-IC, 80-IE, 92BA, 254(1), R. 29 of the ITAT Rules, 1963]

S. 90: Double taxation relief- Non-resident-Rights Entitlement-Capital gains-Rights entitlement distinct from shares-Taxable only in State of residence- DTAA-India-Ireland [[Art. 13(4), 13(5), 13(6), Companies Act, 2013, S. 62]