S. 143(3): Assessment-Amalgamation intimated to Income-tax authorities which has merged-Assessment proceedings against non existing company not valid-Participation in the proceedings by the assessee cannot operate as an estoppel against law. [Art. 226]

S.143(3): Assessment-Principle of natural justice-Order passed without giving assessee adequate opportunity of hearing-Order is set aside.[Art. 226]

S. 143(3): Assessment-Existence of alternate remedy-Person who fails to avail of opportunity of being heard-No violation of principles of natural justice if order is passed-Writ petition is dismissed. [S. 246A, Art. 226]

S. 143(3): Assessment-Accounts-Rejection of books of account-Estimation of profits-Tribunal deleting addition to income by estimating profit-Justified.[S. 133(6), 144, 260A]

S.143(3): Assessment-Principal of natural justice-Order passed set aside. [Art. 226]

S. 143(3): Assessment-Service of notice-Change of address-Notices sent to old address provided by assessee in revised return-Department aware of new address while passing order of refund for subsequent assessment year Mistake due to adoption of mode of communication electronically-Assessment order quashed-Matter remanded with direction to pass speaking order within 45 days [S.69, 282, Rule 127]

S. 132(3) : Prohibitory order-valuable article-Liquor bottles are valuable articles within the meaning of section 132. Liquor bottles can be seized-Prohibitory order in respect of liquor bottles-Not valid.[S. 132, 133(1)]

S. 127 : Power to transfer cases-Search and seizure-Registered office of assessee in Coimbatore Seizure of incriminating documents directly linking involvement of assessee into business of lotteries carried out within jurisdiction of Kolkata Circle Transfer notification from Coimbatore to Kolkata-Incriminating material with regard to involvement of assessee in lottery business for evasion of taxes within Kolkata jurisdiction-Principal Commissioner rightly transferred assessee’s case from Coimbatore to Kolkata where sufficient material for assessment existed. [S. 132, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on delayed receivables-Selection of comparables-Exclusion of comparables by Tribunal on ground of functional dissimilarities-Order of Tribunal affirmed. [S.92B, 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Order of Tribunal affirmed.[S.260A]