S. 147 : Reassessment-No addition was made in respect of reasons recorded-Addition of long term as bogus-Reassessment is held to be bad in law. [S. 148]

S. 147 : Reassessment-With in four years-Information from Investigation wing-Client code modification-Recording of incorrect and wrong fact and wrong provision-Approval in mechanical manner Reassessment is held to be not valid. [S. 147(b), 148, 151]

S. 147 : Reassessment-Wrongly mentioning Section 147(b)-Not curable defects under Section 292B-Reassessment is bad in law. [S.148, 292B]

S. 147 : Reassessment-Search and seizure-Seized ground not related to the assessee-Reassessment is bad in law. [S. 132]

S. 147 : Reassessment-After the expiry of four years-Transfer pricing-Arm’s length price-Tribunal order in earlier year assessment years-No failure to disclose material facts-Reassessment is not valid. [S. 148]

S. 143(3) : Assessment-Jurisdiction-Filing returns at Meerut-Notice for scrutiny assessment issued by Officer at Malegaon-No material to show how or why case transferred-Notice by Officer not having jurisdiction-Assessment invalid. [S. 127, 143(2)]

S. 143(3) : Assessment-Unexplained money-Cash found during search-Sale of scrap-Reflected in balance sheet-Addition cannot be made. [S. 69, 69C, 132]

S. 143(3) : Assessment-Protective assessment-Director-Substantive addition in hands of company deleted-Protective assessment in hands of director not sustainable. [S.179, 292C]

S. 92C : Transfer pricing-Arm’s length price-Arm’s Length Price-Most Appropriate Method-Assembling goods partly purchased from its associated enterprise and partly developed by its own vendor-Resale Price Method adopted is not appropriate-Transactional Net Margin Method, Appropriate. [S. 144C]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Transfer pricing adjustment to be restricted to International Transactions rather than entity level transactions. [S. 92(1)]