S.147:Reassessment — Accommodation entries- Share application and share premium- No failure to disclose any material facts – Assessing Officer not mentioning names of parties from whom receipt of accommodation entry in reasons — Reassessment held to be not valid.[ S.68 , 148 ]

S.143(3):Assessment — Conversion of limited scrutiny into complete scrutiny — Assessing Officer is bound to follow the instructions -Prior approval from competent authority mandatory —In the absence of communication in writing to Assessing Officer about approval, assumption of jurisdiction by Assessing Officer invalid .[ S.54B ]

S.115JB: Book Profits — Subsidy received in form of Excise Duty refund for establishment of new industrial undertaking — Capital subsidy not liable to tax — Excludible from computation of book profits.

S. 115JB : Book profit – Retention money – Not to be considered for computing book profits – Exemption under section 80IA is not allowable while computing book profit- Secondary and higher education cess- Deduction can be claimed in appellate proceedings [ S. 40(a)(i), 80IA 254(1) ]

S.115BBE: Tax on income- Unexplained money —Part of unrecorded sales Addition Cannot be made- Surrendered income – Business income -Eligible deduction under section 80JJA . [ S.69A, 80JJA ]

S. 92CA :Reference to transfer pricing officer -Arm’s length price —Computing Arm’s Length Price without referring matter to Transfer Pricing Officer — Transfer adjustment vitiated – Draft assessment order does not become final assessment order simply by issuing corrigendum — Draft assessment order not valid. [ S.92CA(3) 144C ]

S. 92C : Transfer pricing – Arm’s length price – Comparable Benchmarking of Transaction — Marketing support services same functions – Can be treated as comparable —Deriving its income from manufacturing or trading and indenting services — Not good Comparable for company rendering market support services.

S. 92C : Transfer pricing – Arm’s length price – Debt-free company —Adjustment in relation to notional interest on overdue receivables is held to be not justified- Comparable – Company having controlled transactions — High brand value and high turnover of company —Held not comparables.

S. 80IB: Industrial undertakings – Sub-Licensing income — Royalty — Not related to manufacturing activity – Income excludible on net basis after adjusting loyalty paid against sub-licensing income [ S.80IC ]

S. 74 : Losses – Long-term capital loss — Reduction of share capital — Amounts to transfer —Loss arising due to cancellation of shares allowable as long-term capital loss eligible to be carried forward to subsequent years [ S.2(47) ]