S. 5 : Scope of total income-Wheeling charges-Uncertainty of receiving-Method of accounting-Not assessable as income for the relevant year. [S.4, 145]

S. 2(22)(e) : Dividend-Deemed dividend-Loan-Not share holder of the Company-Not assessable as deemed dividend.

S. 2(14)(iii) : Capital asset-Agricultural land- land was situated 40 k.m. away from municipality – Agricultural activities were carried out in land, there were standing banana crops as well as coconut trees, etc.-Approval from Joint Director, Directorate of Town and Country Planning [‘DTCP’] for conversion of land for non-agricultural purpose prior to execution of sale deed-Not liable to capital gain tax. [S. 45]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Stamp valuation – Date of agreement – Date of registration- Possible view – Revision is held to be not valid [ S.43CA ]

S. 153 : Assessment –Limitation – Transfer pricing -Reference to dispute resolution panel -Time limit for pass Transfer pricing order- Before 60 days prior to the date on which the period of limitation referred to section 153 expires – Order passed on 1 -11-2019 – Barred by limitation by one day – Alternative remedy is not an absolute bar to entertain the writ petition . [ S.92CA(3) ,144C Art , 226 ]

S. 147 : Reassessment – No addition was made on reasons recorded – Additions made on any other income which does not form part of reasons recorded cannot be sustained [S.2(22)(e ), 148 ]

S. 147 : Reassessment –With in four years-Change of opinion- Oversight ,inadvertence or mistake of Assessing Officer discovered on reconsideration of same material – Reassessment is not permissible . [ S.148, Art , 226 ]

S. 45: Capital gains- Advance received -Sale not materialised for gains – Matter remanded to the Assessing Officer for look in to genuineness of the Transaction . [ S.2(47) (v), Transfer of property Act , 1882 , S.53 ]

S. 45 : Capital gains – Valuation of shares – Sale consideration disclosed in the share purchase agreement ought to be adopted for calculating long term capital gains . [ S.48 , 50CA ]

S.45: Capital gains- Penny stock- Jump of share price of 1849.2 % The Assessing Officer has neither conducted any enquiry nor brought any clinching piece of evidence to disprove the evidence produced – Addition cannot be made as cash credits [ S.10(38) , 68 , 131, 133(6)]