S. 153C : Assessment-Income of any other person-Search-Recording of satisfaction-The documents were transmitted to the AO of the assessee, based on which he had rightly initiated the proceeding under S. 153C-The law is amendment of S. 153C w.e.f. 1st Oct., 2014-Incriminating material is found-Assessment is valid-Payment made to tenant is not in respect of said plot-Full consideration is assessable as income. [S. 132]

S. 148: Reassessment-Notice-Non-resident-Non jurisdictional AO-Revenue could not demonstrate that when the notice was issued on 30th March, 2022, ITO, Ajmer, had valid jurisdiction over the assessee-Reassessment is quashed.[S. 147]

S. 147 : Reassessment-Cash deposit-Substantial cash deposit-Return not filed-Reassessment notice is valid. [S. 68,115BBE, 148]

S. 147: Reassessment-Report of Investigation Wing-No tangible material-Reassessment is bad in law-Cash credits-Identity and creditworthiness is established-Addition is deleted. [S.68 148]

S. 147: Reassessment-Survey-Facilitating dubious transactions by accepting huge cash deposits from suspicious/unidentified entities and thereafter transferred most of these amounts to various other suspicious entities-Reassessment notice is valid.[S.133A, 148]

S: 145: Method of accounting-Project completion method-Advance from customers-Sale of 54 units-Neither sales were effected nor the possession of the flats were handed over to the purchasers during the relevant year-CIT(A) was not justified in sustaining the ad hoc addition of 10 per cent of the agreed value of the flats and also ad-hoc disallowance of common expenses. [S. 4, 37(1)]

S. 143(1) : Assessment-Intimation-Prima facie adjustment-Inclusion of excise duty in the turnover for determining rate of tax-The adjustment made while processing the return is not sustainable. [S. 44AB,143(1)(a), 145A]

S. 115JB : Company-Book profit-The provision of S. 115JB is not applicable to Banking companies.[The Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970, S. 11, Companies Act, 2013, S.3, 129]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivables-Interest on outstanding receivables from AE-International transaction-60 days and 240 days-The arm’s length interest rate on similar foreign currency receivables/advances is to be taken as LIBOR+200 points. [S.92B]

S. 90 : Double taxation relief-Salary received-Services rendered in Australia-Not taxable in India-DTAA-India-Australia. [S.5, 9(1)(ii) 15, Art. 4(1), 15(1)]