S. 147 : Reassessment- With in four years- Accommodation entries- Shell company- Deposit of demonetized cash- Sales Borrowed satisfaction- Not independently applied the mind- Reassessment notice and order disposing the objection was quashed-Delay of 354 days- SLP of Revenue is dismissed on account of delay as well as on merits. [S. 69A, 143(1), 148, Art.136]

S. 144C : Reference to dispute resolution panel- Assessment-Mandatory condition-Order passed without following procedure- Order is quashed.[S.292B Art. 226]

S. 144B : Faceless Assessment-Jurisdiction of Assessing Officer-Territorial Jurisdiction- Additional Commissioner of National Faceless Assessment Centre Vested with Jurisdiction to issue notice- Appeal and rectification application filed- Writ is not maintainable. [S.119(2), 120, 124 (2), 143(2) 154, 246A, General Clauses Act, 1897, S. 24, Art. 226]

S. 144 : Best judgment assessment-Estimation of gross receipt-Special Audit Report —Special Audit Report for earlier assessment year cannot be basis to make addition for later assessment year- Matter remanded to Assessing Officer for re computation of income. [S. 37, 142(2A), Art. 226]

S. 143(3): Assessment- Principle of natural justice-Reply of assessee is not considered- Order is set aside. [Art. 226]

S. 132A : Powers- Requisition of books of account- Cash seizure- Reassessment notice- Review petition —Information provided under Right to Information Act incorrect-Review petition dismissed.[147, 148, 148A, Art. 226]

S. 119 : Central Board of Direct Taxes- Circular- Delay in filing return- Condonation of delay- National Company Law Tribunal- Revised books of account- Genuine hardship- Power vested in Authority to be judicially exercised- The assessee could file before the jurisdictional Assessing Officer physical returns of income based on books of account revised under section 130(2) of the 2013 Act, as taken on record by the National Company Law Tribunal for the assessment years 2015-16 to 2020-21 within the time stipulated in this order- SLP of Revenue is dismissed. [S. 119(2)(b). 139(4), Companies Act, 2013, S. 130, Art. 136]

S. 115JB : Company- Book profit-Long-term capital gains-Order of Tribunal allowing the exemption is affirmed. [S. 10(38), 260A]

S. 92CA : Transfer pricing Reference to Transfer Pricing Officer- Arm’s Length price- Avoidance of tax- Comparables- Objections of assessee on account of functional dissimilarities is not considered by Tribunal-Matter remanded to Transfer Pricing Officer.[S.92CA(3), 254(1)]

S. 92CA : Transfer pricing Reference to Transfer Pricing Officer- Arm’s Length price- Avoidance of tax- Net profit margin-That Profit margins required to be compared with profit margins of enterprise and not that of any sub-unit or division of enterprise-Res Judicata- Once accepted in earlier year as initial year- Thee same has to be accepted- Company- Splitting transactions unit wise for determining Arm’s Length Price would not be apposite —Order of Tribunal holding payroll taxes as allowable expenditure is not erroneous- Expression an international transaction is to be construed in plural. [S. 2(31),10A, 92CA(3), 92F(iii) R.10A]