S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Business expenditure-Discovery appreciation plan (DAP)-Material for reopening assessment had been gathered from assessment record of subsequent year-Reasons recorded stated that the claim was allowed by mistake-Change of opinion-Notice and order disposing the objection is set aside. [S. 37(1),143(3), Art. 226]
S.147: Reassessment-After the expiry of four years-Disallowance of expenditure-Exempt income-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed by High Court-Delay of 457 days-SLP of Revenue is dismissed on the ground that reasons assigned are neither satisfactory nor sufficient in law to condone the delay of 457 days. [S. 14A, 148, 263, Art. 136]
S. 144C : Reference to dispute resolution panel-Pendency of objection-Order is set aside. [Art. 226]
S. 144 : Best judgment assessment-Pendency of appeal and revision-Assessment order is stayed till proceedings before Appellate Authority or Revisional Authority were decided. [S. 144B, 148, 246A, 264, Art. 226]
S. 143(3): Assessment-Error in heading was result of an inadvertent systemic error-Clarification issued by the Assessing Officer-Writ petition is dismissed. [S. 144C, Art. 226]
S. 119 : Central Board of Direct Taxes-Circular-Return of income-Delay of 216 days-Delay is not explained satisfactorily-Rejection of application for condonation of delay in filing the return is affirmed.[S. 80P, 119(2)(b), 139, Art. 226]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Brand value-Entities having high brand value and, therefore, being able to command greater profits could not be selected as comparables-Order of Tribunal is set aside.[S. 260A]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Trading of imported luxury goods-Resale price method (RPM) is most appropriate method. [S. 260A]
S. 69A : Unexplained money-Search-Deposit in bank account-Debit card in joint name-Matter remanded to produce bank account. [S.260A]
S. 68 : Cash credits-Unsecured loan-Furnished documents to prove identity, genuineness and credit worthiness of parties-Matter remanded back to the Assessing Officer for fresh consideration. [S. 143(3), Art. 226]