S. 153A : Assessment-Search-Third person-Loose sheets pertaining to earlier years were found in third party premises-No inference could be drawn against assessee qua relevant assessment year-Theory of extrapolation-Not applicable on mere theoretical or hypothetical basis-Natural justice-Failure to provide an opportunity of cross examination the witness which the Department relied on-Addition cannot be made-Amalgamation-Assessing Officer framing assessment separately in name of Amalgamated Company, in spite of furnishing information-Order bad in law. [S. 68, 69C, 132]

S. 147 : Reassessment-Incriminating material found during search-Accommodation entries-Reassessment is held to be justified-Failure to prove identity of investor, its creditworthiness and genuineness of transaction-Addition Justified. [S. 68, 148]

S. 147 : Reassessment-Audit party note is not information-No failure to disclose material facts-Reassessment is not valid-The tax effect below prescribed limit-Appeal of department is dismissed. [S. 148, 253]

S. 147 : Reassessment -Incorrect assumption of fact-Recording of reason that the assessee has not filed the return-Return was filed before recording of reasons-Reassessment is held to be invalid. [S. 148]

S. 143(3) : Assessment-Amalgamation of Companies-Additional ground-Legal issue-Non issue of notice-Assessment is held to be void ab initio. [S. 143(2), 254(1)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover filter-Turnover of more than Rs.200 crores was excluded-Market support services-Operating cost Matter remanded. [S. 92]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Companies Engaged In Providing High-End Integrated Services, Having Huge Brand Name And Significant Intangibles Cannot Be Compared-Gains or loss arising from Fluctuation of Foreign Currency to be considered as operating in nature-working capital adjustment to be allowed on actual basis without any restriction.-Directions of Dispute Resolution Panel cannot be construed as setting aside of issue to Transfer Pricing Officer. [S. 92CA, 144C(8)]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method (TNMM)-Held to be appropriate method-Remanded TPO to apply TNMM method. [S. 92]

S. 68 : Cash credits-Purchases-Credit balance outstanding-Deleted the addition.

S. 56 : Income from other sources-Allotment of shares-Valuation Discounted Cash Flow Method-Assessing Officer cannot change the method of valuation-Matter remanded. [S. 56 (2)(viib)]