S. 149: Reassessment-Time limit for notice-Notices under new regime issued beyond limitation prescribed by Supreme Court-Proceedings time-barred-Withdrawal of approval under section 10(23C)(vi) invalid-Second proviso-Applicable only from assessment year 2022-23-Reference to Principal Commissioner for earlier years invalid-Withdrawal of approval-Jurisdiction-Reference made to wrong authority-Order without jurisdiction.[S 10(23C)(vi) 148, 148A(b), 148A(d)]

S. 148: Reassessment-Non-resident-Notice issued by non-jurisdictional Assessing Officer-Assessment framed by Assessing Officer (International Taxation) on same notice-Reassessment void-Delay of 57 days was condoned. [S. 147, 254(1)]

S. 145: Method of accounting-Percentage Completion Method-Consistently followed and accepted-Revenue cannot substitute completed sales method without pointing out defects-Percentage Completion Method-Double taxation avoided-Addition deleted.

S. 143(2): Assessment-Notice-Return filed in response to notice under section 148 not e-verified-Return non est-Notice under section 143(2) not mandatory.[S. 139, 148]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Adjustment to be confined to international transactions with Associated Enterprises–Comparables-Functional similarity-Government company not to be excluded merely because of Government ownership-Matter remanded-Trading segment-Commission earned on direct sales by Associated Enterprises to third-party customers-Not part of trading activity-Transactional Net Margin Method-Global sales and marketing expenditure-Operating cost.[S.92CA]

S. 80P: Co-operative societies-Deduction-Belated return-Deduction under section 80P cannot be denied merely because the return was filed after the due date. [S.80AC(ii), 139(1), 143(1)]

S. 80G: Donation-Corporate Social Responsibility (CSR) expenditure-Donation to charitable institution-Deduction allowable.-Appeal to Appellate Tribunal-Co-ordinate Bench decision-Binding precedent.[S. 254(1)]

S. 80G: Donation-Deduction-Corporate Social Responsibility expenditure-No bar to deduction if conditions of section 80G are fulfilled.[S. 37(1)]

S. 68 : Cash credits-Capital gains-Penny stock-Short-term capital loss-Addition based only on Investigation Wing and SEBI reports-Tuni Textile Ltd-Blue Circle Ltd-No independent enquiry-Loss allowable.[S. 10(38), 45]

S. 68: Cash credits-Demonetisation-Cash deposits out of recorded cash sales-Books of account not rejected-Addition deleted-Assessment-Protective addition-Cash sales-Substantive addition pending in purchaser’s case-Matter remanded.[S.115BBE, 143(3), 145]