S. 115O : Domestic companies – Tax on distributed profits – Buy back of shares – Approval of Scheme – Capital gains or dividend income – Direction to file an appeal before CIT (A) and also finding on merits – Decision on merit is held to be not valid – Direction to file an appeal is held to be justified. [ S. 2 (22)(d), 10 (34A), 46A, 115QA, 246A Art , 226 ]

S.148: Reassessment —Notice in name of dead person — Held to be not valid — Not a defect curable under S. 292B of the Act – Intimation by legal Representative that noticee was dead is not a participation in reassessment proceedings [ S.147 , 292B Art .226 ]

S. 133 : Power to call for information – Authorities – ITO (Intelligence ) is an authority to issue notice under section 133(6) to the assessee Co -Operative banks prior to CBDT Notification No 77 of 2014 dt 10 -12 -2014 [ S. 90, 90A, 120, 124, 133(6), 272A(2)(c)]

S. 40(a)(ia): Amounts not deductible – Deduction at source – Belated filing of form No .26Q- Matter remanded to Assessing Officer – No substantial question of law [ S.194C(7) ]

S. 245R : Advance rulings – Mere issue of notice under section 143 (2) is not an bar for approaching the AAR- Writ petition of revenue is dismissed .[ S.143 (2), 245R(2) ]

S. 158BE : Block assessment – Time limit – Panchanama – Approval was taken -Notice u/s 143 (2) was issued – Search in more than one premises – More than one Panachnama which state that search continued and prohibitory order was issued – Vacation of prohibitory order has to be considered as conclusion of search- Order is not barred by limitation . [ S. 132(3) , 143 (2) , 158BG , Art , 226 ]

S. 147 : Reassessment – Reasons communicated -Participated in the proceedings – If relevant germane reasons exist and have been communicated to the assessee that is enough for reassessment proceedings to hold the field- Writ is not maintainable [ S.148 , Art , 226 ]

S. 143(2) : Assessment – Notice – Barred by limitation -Defective return – On removal of defect the return would relate back to the date of filing of the original return- Period of limitation has to be computed from the filing of original return – Order is bad in law [S.139 , Art . 226 ]

S. 92C : Transfer pricing – Arm’s length price – Comparables- Different financial years – Rejection of comparable- Question of fact – Exempted income – Disallowance of expenses – Question of fact [ S.260A ]

S. 92C : Transfer pricing – Arm’s length price – Providing market services to Associated enterprises – Deletion of addition is held to be justified – No question of law [ S.260A ]