S. 147 : Reassessment-Income of any other person-Search-Reassessment is not valid when the assessment out have been done under section 153C of the Act as per non obstante provision-Cross examination denied-Addition as cash credit is held to be not justified. [S. 68, 132, 153C]

S. 147 : Reassessment-After the expiry of four years-Capital gains-Report from investigation wing-No tangible material-Reassessment is held to be in valid. [S. 50C, 148]

S. 147 : Reassessment-After the expiry of four years-No failure to truly and fully disclose all material facts Necessary For Assessment-Notice not valid. [S. 143(2), 148]

S. 144C : Reference to dispute resolution panel-Assessment-Limitation-Amalgamation of companies-Draft assessment order passed in name of amalgamated company-Not a curable defect-Order void ab initio. [S. 143(3), 144C(15)(b), 153, 292B]

S. 143(3) : Assessment-Bogus purchases-Addition based on the report of Inspector-Remand report no adverse comment-Deletion of addition is held to be justified-No defects in the books of account-Addition cannot be made.

S. 115JB : Book profit-Provision for diminution in value of investment and provision for non-performing assets-Actual write-Off of sums-Sums not provisions-To be excluded from book profits.

S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-Software Development Service-Companies having huge brand value and engaging in sale of software products, developing mobile enterprise applications and solutions not functionally comparable to be excluded from list of comparables-Interest due on receivable outstanding-Not charging others-Addition cannot be made. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Direct Sales Compensation-Direction to Assessing Officer to adopt average commission rate of 3.93 Per Cent. as appropriate rate for benchmarking-Bad debts written off-Adjustment made towards bad debts written off to be deleted-Royalty-Matter remanded.-Order pronounced much after the expiry of 90 days. [S. 254(1)]

S. 80IA : Industrial undertakings-Wind mills-Initial assessment year-Option to choose year within block of 15 years from commencement of business.

S. 68 : Cash credits-Bogus purchases-Addition of entire amount payable to six sundry creditors is held to be not justified-GP estimate of 16% on unsubstantiated purchases from six creditors was up held. Adoption of Gross Profit Rate Of 16 Per Cent.