S. 132 : Search and seizure –Stock in trade-Burden of proving goods constituted stock-in-trade of business, lies on assessee.[S. 131(IA), 132(1)(iii),132(4) Art. 226]
S. 132 : Search and seizure –Stock in trade-Burden of proving goods constituted stock-in-trade of business, lies on assessee.[S. 131(IA), 132(1)(iii),132(4) Art. 226]
S. 132 : Search and seizure-Satisfaction note-Reasons recorded-Non-compliance with statutory requirements under section 132(1) vitiated search and seizure operations. [S. 132(1), Art. 226]
S. 127 : Power to transfer cases-Denial of reasonable time to respond to notice-Matter remitted to Principal Commissioner to afford personal hearing to assessee and decide in accordance with law.[Art.226]
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Disallowance of expenditure-Existence of international transaction must be established and not inferred-Burden on Revenue to prove existence of international transaction-Amendment introducing deeming fiction in section 92B(2) with effect from 1-4-2015 not applicable to assessment years 2009-2010 and 2012-2013-Orders of assessment set aside. [S. 92B, 92CA, 92D, 92F, 260A]
S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Contractor or developer-Road project-No substantial question of law.[S.80IA(4)]
S. 80HHC : Export business-Search and seizure-Block assessment-Genuine export sales-Order of Tribunal allowing the benefit was affirmed. [S. 132, 158BC, 260A.]
S. 80DD : Medical treatment of dependent-Disability-Medical treatment of handicapped dependent-Amendment made by Finance Act, 2022 to section 80DD could not be applied retrospectively to policies taken prior to 2014 as it was not in the interest of disabled persons-Court cannot give retrospective operation to insurance contract which is a commercial contract.[S.80DD(2)(a), Finance Act, 2022, S.21, Art. 32, 142]
S. 69C : Unexplained expenditure-Search-Block assessment-Failure to issue cross examination-Order deleting the addition was affirmed.[S.69A, 132(4), 158BC, 260A]
S. 68 : Cash credits-Share premium-Notices served on companies returning unserved Inspector reporting companies non-existent-Order of Tribunal affirmed-No question of law. [S. 133(6), 260A]
S. 68: Cash credits-Not explained the source-Order of High Court affirming the addition was affirmed-SLP of assessee dismissed on the ground of delay of 388 days and on merits. [Art. 136]