S. 151: Reassessment – Sanction for issue of notice -Validity of unsigned approval- The approval under section 151 dated 30-3-2021 was unsigned, the Assessing Officer had no valid jurisdiction to issue the notice under section 148; consequently, the notice under section 148 and all consequential proceedings were quashed- The Court also held that section 292BC, being applicable retrospectively from 1-4-2021, had no application to the approval granted on 30-3-2021. [ S. 148 , 282A(2), 292BC , Art . 226 ]

S.142(2A): Inquiry before assessment-Special audit-Mandatory statutory procedure not followed-Assessment void ab initio.[S. 142(2C), 143(3) 145(3)]

S. 115BAB: Tax on new manufacturing domestic companies-Concessional tax rate-Manufacturing company-Option once exercised continues for subsequent years-Adjustment under section 143(1) not permissible without opportunity of hearing. [S.143(1)]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Working capital adjustment-Comparables selected by Transfer Pricing Officer-Matter remanded-Adjustment on overdue receivables consequential.[S.92CA]

S. 56: Income from other sources-Immovable property-Stamp duty valuation to be adopted as on date of allotment-Addition deleted.[S. 56(2(vii)(b)]

S.43B: Deductions on actual payment-Customs duty paid under protest-Refund offered to tax in subsequent year-Disallowance would result in double taxation-Deduction allowable-Addition was deleted. [S. 143(3)]

S. 40A(3): Business expenditure-Cash payments-Television serial production-Advances to cashier for petty expenses-Matter remanded for verification.

S. 40(a)(ia): Amounts not deductible-Deduction at source-Business expenditure-Generator hire charges and diesel reimbursement-No tax deductible on reimbursement of fuel cost-Matter partly restored-Professional fees-Tax deducted at source-Disallowance deleted-Purchase of ready-made shooting set-Sale transaction-Tax deduction at source not applicable.[S.194C, 194J]

S. 12AB : Procedure for fresh registration-Clause permitting buy-back of shares in Articles of Association-Matter remanded-Commissioner exceeded scope of enquiry by examining past claim of exemption under sections 11 and 12-Payments to specified persons-One more opportunity to explain-Matter remanded.[S. 11, 12, 13]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Non-resident-Reimbursement of travel agent and other expenses-No services rendered by assessee-Not Fees for Technical Services or Fees for Included Services-Marketing and Reservation Contribution-India-USA DTAA-Not Fees for Technical Services or Fees for Included Services-Not taxable in India-DTAA-India-USA.[Art. 12.]