S. 151 : Reassessment-Sanction for issue of notice-Sanction of Joint Commissioner-Sanction obtained from commissioner-Notice not valid. [S. 143(1), 147, 148, 151(2)]

S. 147 : Reassessment-Not making any additions on grounds initially raised in notice or in reasons recorded-Not entitled to make additions on other grounds-Sanction-Consolidated approval in group case without recording qua each case-Reassessment invalid-Legal ground on jurisdiction can be raised first time before Appellate Tribunal [S. 2(22)(e), 148 (2), 151, 254(1)].

S. 147 : Reassessment-After the expiry of four years-No failure To Disclose material facts-Reassessment not valid. [S. 148]

S. 145 : Method of accounting-Non maintenance of stock register can be the ground to reject the books of account. [S. 145(3)]

S. 143(3) : Assessment-Deduction not claimed in return but later by letter to Assessing Officer during assessment proceedings-Appellate Authority Can Consider-Foreign exchange loss-Loss pertaining to current year lone is allowable. [S. 28(i), 139, Art. 265]

S. 143(3) : Assessment-Bogus purchases-Sales not doubted-Purchases to be treated as genuine. [145 (3)]

S. 143(3) : Assessment-Income from undisclosed sources-Ad hoc addition basis of third party information-Matter remanded to the Assessing Officer. [S. 194J]

S. 143(3) : Assessment-Amalgamation-Assessment order made in name of amalgamating company-Entity non-existent on date of passing of order-Order null and void.

S. 92C : Transfer pricing-Arm’s length price-Comparable-Having vastly higher turnover cannot be used-Amalgamation not reason For exclusion-Income-tax Authorities-Transfer Pricing Officer-Include additional Commissioner-Order passed by Additional Commissioner is valid. [S. 2(28C), 92CA, 117(1)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Loss making companies to be excluded-High margin cannot be excluded unless backed by certain extraordinary events-Risk adjustment to be considered-Adjustment to be worked out applying average profit level indicator of comparables to cost of international transactions and not on its sale turnover.