S. 148 : Reassessment-Notice-Recording of reason stating that the assessee failed to file return of income-Contradictory to facts on record-Mechanical sanction-Notice u/s. 143 (2) was issued on same day on which the assessee appeared in response to notice u/s 148-Order was quashed. [S. 143 (2) 143(3), 147, 151]
S. 148 : Reassessment-Notice-Recording of reason stating that the assessee failed to file return of income-Contradictory to facts on record-Order was quashed. [S. 143(3), 147]
S. 148 : Reassessment-Notice-Notice was not served-Approval granted was of mechanical manner-Legal issue-Additional ground was admitted-Reassessment proceedings is quashed. [S. 144, 147, 254(1), 282(1), Civil Procedure Code,1908, Order V rule 12, Order III rule 6]
S. 147 : Reassessment-Jurisdiction-Notice issued by one Officer-Reassessment order was passed by another circle-No order by Competent Authority transferring case-Order was liable to be quashed. [S. 127(2), 144, 148]
S. 147 : Reassessment-Carbon credit-Capital receipt-Reassessment notice to contrary decision of High Court-Held to be in valid. [S. 4, 148]
S. 144 : Best judgment assessment-Ad-hoc disallowance on percentage basis-Books of account audited by chartered accountant-Ad-hoc disallowance was deleted [S. 37(1), 145(3)]
S. 143(2) : Assessment-Notice issued by the Assessing Officer not having jurisdiction over assessee-Additional ground admitted-Not curable defects u/s .292BB of the Act-Assessment order was quashed. [S. 127(4), 254(1), 292BB]
S. 115JB : Book profit-Provision created for premium payable on redemption of debentures-Ascertained liability-Not to be added to book profits.
S. 92C : Transfer pricing-Arm’s length price-Software development service-Comparable-Companies providing software development services as well as sale of software products-Directed to exclude from the final set of comparbles. [S. 92CA(3)]
S. 92C : Transfer pricing-Arm’s length price-Payment of professional fees-No adjustment required-Assessing Officer cannot disallow expenses. [S. 37(1)]