S. 147 : Reassessment-Accommodation entries-Reasons supplied was not the same reason recorded-Reopening of assessment was held to be not sustainable. [S. 148]
S. 147 : Reassessment-Accommodation entries-Reasons supplied was not the same reason recorded-Reopening of assessment was held to be not sustainable. [S. 148]
S. 147 : Reassessment-Survey-Inspectors report was not shown-Cross examination of witness was not provided-Reassessment was quashed. [S. 68, 148]
S. 143(3) : Assessment-Amalgamation of Banks by Gazette Notification-Assessment in the name of amalgamated or merged Entity-Assessment in the name of non-existent entities is held to be not sustainable.
S. 143(3) : Assessment-Income from undisclosed sources-Survey-Discrepancy of stock-Addition can be made only to the extent of profit element in sales considering the average sale price as ascertainable from sales recorded and not entire sale proceeds. [S. 133A]
S. 143(3) : Assessment-Bogus purchases-Grey market-Affidavit before Sales tax department-Only profit element can be estimated. [S. 133(6)]
S. 142(2A) : Inquiry before assessment-Special audit-Writ petition was pending-No stay of proceedings-Assessment completed beyond statutorily prescribed period-Barred by limitation. [S. 153A, 153B
S. 92C : Transfer pricing-Arm’s length price-Advertisement and publicity expenses-Margin earned higher than the third party transactions-Adjustment made was deleted.
S. 92C : Transfer pricing-Arm’s length price-Consultancy services-Matter remanded.
S. 92C : Transfer pricing-Arm’s length price-Functional dissimilarity-Product company having inventories and undertaking very high level research work-Excluded from list of comparable Companies. [S. 92CA]
S. 92C : Transfer pricing-Arm’s length price-Functionally different-Cannot be comparable.