S. 144B : Faceless Assessment-Principle of natural justice-Statutory mandate-Failure to grant seven days time to respond to show-cause notice-Proposing variation in income and afford personal hearing-Failure to give video conference-Matter remanded. [S. 143(3), 144B(6)(vii), Art.226]

S. 143(3): Assessment-Closing stock-Estimation of gross profit-Bullion trading-Stock register maintained, Sales, purchases, stock tally, stock register and delivery challans are produced-Order of Tribunal deleting the addition. is affirmed.[S. 260A]

S. 143(3) : Assessment-Principle of natural justice-Video conference is not granted-Agricultural income-Exemption denied on the ground that certificate of Village Administration Officer was furnished in Tamil-Assessment is set aside-The assessee is directed to produce English translation. [S. 10(1), Art. 226]

S. 143(1) : Assessment-Intimation-Revised return filed within limitation period-Scrutiny assessment ignoring revised return not valid-Processing of return under Section 143(1)(A) not an assessment order-Penalty Not Imposable [S. 143(1)(a), 143(IA) 143(3), 260A, 271 (1)(c)]

S. 92CA : Transfer pricing Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Assessing Officer cannot make Transfer pricing adjustment which is not considered by Transfer Pricing Officer. [S.92C, 144C, Art. 226]

S. 92CA : Transfer pricing Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Parent company of subsidiary-Not controlling and determining quantity of production-Sales to associated enterprises under individual contracts-Not payment of royalty-Not profit-shifting mechanism even if royalty embedded in sale price-Contract manufacturer-Royalty payment by subsidiary to its parent company abroad-Comparable to those in open market-Transfer pricing adjustment of royalty is not justified-No substantial question of law. [S.92C, 260A, R.10A, 10E]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Order in conformity with directions of Supreme Court guidelines-No substantial question of law.[S. 260A]

S. 80IA : Industrial undertakings-Enterprises engaged in infrastructure development-Manufacture or production of GITTI from sand stone blocks-Amounts to manufacture or production.[S.80IB, 260A]

S. 68 : Cash credits-Sundry credits and unsecured Loans-Responding to notice under Section 133(6) and confirming transactions through banks in their statements under Section 131-Order of Tribunal is affirmed-No substantial question of law. [S. 131, 133(6), 260A]

S. 68 : Cash credits-Long-term capital gains-Penny stock-Sunrise Asian Ltd-Exemption-Information from Investigation Wing-Presumptions is not corroborated by evidence-Order of Tribunal deleting the addition is affirmed.[S. 10(38), 45, 115BBE, 133(6), 260A]