S. 147: Reassessment-Purchase of agricultural land-MOU on 21-3-2016-Presented before Joint Sub-Registrar on 24-3-2016, falling in financial year 2015-16 relevant to assessment year 2016-17-Reassessment for the assessment year 2017-18 was not valid. [S. 148 ITATR.27, Registration Act, 1908, S. 47]

S. 147: Reassessment-Unexplained investments-No addition was made on the reasons recorded-Reassessment order was quashed and set aside.[S.50C, 69, 148]

S. 145: Method of accounting-Estimation of profit-Decline in gross profit margin-No specific defects or discrepancies in books of account-Appeal of revenue dismissed.

S. 144C: Reference to dispute resolution panel-Dividend-Rate of tax-Singapore tax resident-Mistakenly offered non-taxable capital gains and excess tax on dividends-Assessing Officer and DRP ignored correction request, citing lack of jurisdiction-Tribunal held that DRP can examine such issues under section 144C(8)-Tribunal restored matter to Assessing Officer to verify and allow relief if admissible-DTAA-India-Singapore [S.9(1)(i) 144C(8), Art.10]

S. 144C: Reference to dispute resolution panel-Amalgamation-Non-existent entity-Draft assessment order was passed in the name of a non-existent entity despite the Assessing Officer having been duly informed of amalgamation-Void-ab-initio. [S. 144C (5),292B]

S. 143(3): Assessment-Limited Scrutiny-Depreciation-Goodwill-Increase in share capital-Assessing Officer could not have enlarged scope of limited scrutiny to full scrutiny without prior approval of Jurisdictional Commissioner-Addition made by Assessing Officer disallowing depreciation on goodwill was quashed.[S. 32, 143(2)]

S. 143(1)(a): Assessment-Intimation-Prima facie adjustment Leave encashment-CPC, while processing a return under section 143(1) cannot make any adjustment without issuing any prior intimation as contemplated under the first proviso to section 143(1)(a).[S.10(10AA(ii)]

S. 124: Jurisdiction of Assessing Officers-Reassessment –Notice-Transfer of case-AIR information-Purchase of property-ITO, Bareilly issued notice-Not designated Assessing Officer-Mere mention of a Bareilly address in sale deed could not confer jurisdiction-Notice was quashed as beyond jurisdictional competence and therefore non-est in law-Assessment order was quashed. [S. 124, 144, 147, 148]

S.92BA: Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-Firm-Partner-Capital contribution from partner-Failure to give comparable-Assessing Officer valued at a lower rate based on cost of construction-Addition was affirmed.

S.89A: Relief from taxation in income from retirement benefit account maintained by notified country-Denial of relief-Filed Form No. 10EE for assessment year 2022-23-Option exercised therein would continue to apply to all subsequent years-It would not be mandatory for assessee to file said Form afresh for every assessment year to claim relief under section 89A.[R. 21AAA, Form No 10EE]