S. 153C : Assessment-Income of any other person-Search-Recording satisfaction note by Assessing Officer that material recovered in search related to assessee is mandatory-Assessment made solely on basis of statement recorded during survey of another company without furnishing copy of statement or allowing it opportunity to cross-examine deponent-Statement recorded during survey-Assessment without jurisdiction. [S. 132, 132A, 153A]

S. 153 : Assessment-Limitation-Assessment order passed by Assessing Officer Pursuant To Directions Of Dispute Resolution Panel-Not subject to limitation [S. 143(3), 144C(13)]

S. 147 : Reassessment-Accommodation entries-Share capital-Unsecured loan-Borrowed satisfaction-Non application of mind-Reassessment is held to be bad in law. [S. 69, 148]

S. 144 : Best judgment assessment-Maintaining huge cash balance in particular period-Cash withdrawal from bank-Additions cannot be made on the presumption that the assessee could have discharged sundry creditors instead of having cash in hand. [S. 36(1)(iii), 145(3)]

S. 142(2A) : Inquiry before assessment-Special audit- Appeal maintainable before Appellate Tribunal-Complexity of Books of account established-Order for special audit sustainable. [S. 253]

S. 115JB : Book profit-Statement of accounts drawn in accordance with Companies Act-Disallowance under Income-Tax Act cannot be exporting for computation of book profits-Provision for doubtful trade receivables and advances debited to Profit and Loss Account-Writing off sum from its trade receivables in balance-sheet-Sum loses character of provision-No adjustment Called for-No adjustment on account of corporate Social responsibility expenses and donations-Provision for taxes made by Companies with whom assessee amalgamated-Reversal of unutilised provision for taxes in current Year-Matter remanded for verification-Debenture redemption reserve-Appropriation of profits and not provision for ascertained liability.

S. 92C : Transfer pricing-Arm’s length price-Mere filing sample bill is not sufficient-Burden is on assessee to prove service rendered-Matter remanded-Acting as facilitator and reimbursements were pass-through costs-No adjustment to be made-Dispute Resolution panel-Bound to follow the order of Appellate Tribunal, though the appeal was preferred to High Court. [S. 144C, 254(1)]

S. 92C : Transfer pricing-Arm’s length price-Outstanding Receivables-Interest for realisation of trade advances up to 150 days-Interest for delay above 150 days alone should be considered Prime lending rate should not be considered-Currency in which loan to be repaid. [S. 92B]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Five companies to be excluded from final list of comparables. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Advertisement, marketing and sales promotion expenses-Business Of Distributing-Not a case of adding value to goods-Sale and distribution expenses to be excluded. [S. 92CA(3)]