S. 158BC : Block assessment – Satisfaction – Recorded after competition of assessment – Capital gains – Transfer-A satisfaction note is sine qua non and could be prepared at either of following stages , at the time of or along with the initiation of proceedings against the person searched under section 15C of the Act , along with the assessment proceedings under section 158 BC and immediately after the assessmmeent proceeings are completed under section 158BC of the person sercched – Order of Tribunal is quashed . [ S.2(47)(v) , 45, 132 158BD ]

S. 147 : Reassessment- Reasons communicated and reasons raised are different – Recorded reason was supplied after completion of assessment – Reassessment is bad in law [ S.148 ]

S. 147 : Reassessment – Charitable Trust- Corpus donation – Change of opinion- No new facts – Reassessment is held to be bad in law [ S. 2(15) 11, 12A , 148 Art , 226 ]

S. 144 : Best judgment assessment – Addition made cash deposited during demonetization period. – Addition on account of business income – Violation of principle of natural justice –
Matter remanded to Assessing Officer [ S.142 (1), Art , 226 ]

S. 92C : Transfer pricing – Arm’s length price – Comparable – Test of functional similarity applied by Tribunal is in consonance with legal position discussed herein above— Order of Tribunal is affirmed [ S.92B(2), 260A ]

S. 80G : Donation -Renewal of exemption is held to be justified [ S. 11, 12A, 80G (5)(iii) ]

S. 50B : Capital gains – Slump sale – Complete code – Deletion of addition is held to be valid [ S. 2(19AA), 2(42C), 48, 49 ]

S. 47(v) : Capital gains – Transaction not regarded as transfer – Subsidiary to holding company – Not necessarily whole of the shares of the subsidiary company is held by holding company – A construction which results in rendering a provision redundant must be avoided – Entitle to exemption . [ S.47 (iv)]

S. 37(1) : Business expenditure – Discount to custoners – Higher percentage than discount granted earlier year – Disallowance is arbitrary – Income- tax Authorities must put themselves in the shoes of the assessee and see how a prudent businessman would act -Books of account not rejected – Allowable as business expenditure .

S. 37(1) : Business expenditure – Deferred revenue expenditure – Advertisement publicity and sales promotion – Allowable in the year it was incurred .