S. 147: Reassessment-Within four years-Change of opinion-No new tangible material-Performance guarantee-Deposit-Addition was deleted on merits by CIT(A)-Additional legal ground on reassessment is admitted-Reassessment is quashed on the ground of change of opinion. [S. 37, 69, 148, 254(1), ITAT R 1963.R. 27]

S. 147: Reassessment-Change of jurisdiction-Notice is issued by the Assessing Officer who had jurisdiction-Later case was decentralized-No objection was raised before the Assessing Officer-Ground of jurisdiction is rejected [S. 120, 124, 127 148, 149, 151, 282, 282A, General Clauses Act, 1897, S. 27]

S.147: Reassessment-After the expiry of four years-Audit objection-Re assessment is valid.[S. 148]

S. 143(3): Assessment-limited scrutiny through CASS-Cash credits-The Assessing Officer cannot make addition other than the issue covered under limited scrutiny-CBDT Instruction No. 5 of 2016, dt. 14th July, 2016 [S. 143(2)]

S. 143(3): Assessment-Search-Abatement of assessment-Documents relating to company and directors are seized-Pending assessment is abated-Assessment has to be made under section 153A or 153C-Assessment order is quashed and set a side. [S.68, 132, 153A 153C ]

S. 143(2) : Assessment-Notice-Reassessment-Notice issued beyond time prescribed-Order is null and void.[S. 139(4), 147, 148]

S. 115BBC : Anonymous donations-Determination of tax in certain cases-Charitable and religious purpose-Trust registered under S. 80G can also avail benefit of S. 115BBC(2) (b)-Entitle to benefit.[S.80G, 115BBC(2)(b)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Allocation of common expenses-Allocation done by the TPO on the basis of revenues from the two segments is in order-Adjustment on account of payment of customs duty-No adjustment is allowable on account of the fact that the assessee has paid more customs duty than that paid by the comparables-Most appropriate method-TNMM should be applied in respect of international transaction of sale of finished goods.

S. 80P : Co-operative societies-Interest received from Baroda Rajasthan Gramin Bank Ltd. being a regional rural bank is not a cooperative society-Not entitle to deduction-Interest from central co-operative bank is eligible deduction-Circular No. 6 of 2010, dt. 20th Sept., 2010. [S.80P(2)(d)]

S. 80IA : Industrial undertakings-Qua undertaking and not Qua assessee-Enterprises engaged in infrastructure development-Entire undertaking which developed the industrial park has been transferred-Transfer of undertaking-of Transferee is entitled to deduction-Circular No 799 dt 14-9-1999-Interest on fixed deposits-Not eligible deduction u/s 80IA-Assessable as income from other sources-Interest expenditure for earning of interest is allowable as deduction. [S.56 57(iii), 80IA(4)(iii), 80IA(12) ]