S. 153D : Assessment-Search-Approval-Document Identification Number (DIN)-Additional Commissioner to draft assessment order was without issuance of DIN, final assessment order passed under section 153A on basis of such invalid and non-est approval under section 153D was without sanction of law and was to be quashed.[S.153A]

S. 153C : Assessment-Income of any other person-Search-Additional ground-Document Identification Number-Un explained money-Assessment order neither contained any Document Identification Number nor any reason for non mentioning thereof, assessment order-Violation of Circular No. 19/2019, dated 14-8-2019-Order is quashed. [S. 69A, 143(3)]

S. 153A : Assessment-Search-Limitation-Information-Article was applicable for information that related to period on or after 1-4-2011-Not valid reference-Order is barred by limitation-DTAA-India-Swiss.[S. 143(3), 153B, Art. 26]

S. 147 : Reassessment-Un explained expenditure-Cash purchase-No transaction was entered during the year-Reopening on the basis of statement of N.K. Vora is not valid-Incorrect fact-Reassessment is quashed. [S.69C, 148]

S. 147 : Reassessment-Deemed to accrue or arise in India-Royalties/ fees for technical services-licence fees-AIR information available in AIMS module of ITBA-In year under consideration, neither assessee had made remittances to anyone outside India or in India nor deducted any tax at source-Reassessment is quashed-India-Australia. [S.9(1)(vi), 9(1)(vii), 148, 194E, 195, Art. 12(3)]

S. 147 : Reassessment-Notice-Sale of investment in Indian company by Assessee, a tax resident of Mauritius-No return filed as capital gain was exempt in terms of Article 13(4) of the DTAA-Reopening on the basis of form 15CA filed by the Assessee-No prima facie satisfaction was recorded-Notice and the consequent reassessment order is set aside-DTAA-India-Mauritius.[S. 148, Form 15CA, Art. 13(4)]

S. 145A : Method of accounting in certain cases-Valuation of stock-Valuation of inventories, net of CENVAT-Method followed consistently-No addition could be made on account of CENVAT credit.

S. 145 : Method of accounting-Percentage completion method-No defects in the books of account-No addition can be made on the basis of projected revenue during the proceedings under section 197.[S. 197]

S. 143(3): Assessment-Document Identification No (DIN)-No DIN number was mentioned in the assessment order-Assessment order is invalid-Subsequent separate communication of DIN would be a superfluous exercise.[S. 119]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Distributor of products manufactured by its AE-AMP expenditure incurred in India to promote brand-Not constitute international transaction requiring any TP adjustment.[S.92C]