S. 145 : Method of accounting-Survey-Estimation of income-Assessee has shown net profit of 2 %-AO estimated net profit at 5%-Reported a profit of 8% in earlier years-Estimate of income at 5% is affirmed-Assessment order and intimation bearing DIN were uploaded on revenue’s portal-Assessee can not challenge validity of assessment order for lack of DIN-Assessment-Digital signature-On account of technical issues departmental authorities were prevented from making digital signatures, prompting manual signing of assessment order-Orders were uploaded and sent to assessee’s registered email ID, it was deemed to be authenticated and therefore, assessment order was valid.[S. 133A, 143(3),, 144, 147, 148,156, 271A, 271B, 282A(2)R. 127A]

S. 144C : Reference to dispute resolution panel-Limitation period DRP issued certain directions to Assessing Officer vide order 17-3-2022 and FAO being designated assessment unit was privy to DRP order in April 2022-limitation in extreme case scenario would run from April 2022 and would end on 31-5-2022-Assessment order having been passed on 30-6-2022, is time barred-Transfer of case records by Faceless Assessment Officer (FAO) to a different jurisdiction, i.e., Jurisdictional Assessment Officer (JAO) will not entitle Department to get extension of limitation period for framing assessment. [S. 144B, 144C(13)]

S. 143(2) : Assessment-Notice-Defective return-Limitation- limitation for issuing notice for assuming jurisdiction to frame assessment will run from year in which return of income was filed-Not when defect under section 139(9) is removed-Order is quashed and set aside. [S. 139(9), 143(3) 153]

S. 115BAA: Tax on income of certain domestic companies-Determination of tax in certain cases-Uploaded Form 10-IC electronically on 2-5-2021 i.e. before cut-off date mentioned in CBDT circular No. 6/2022, dated 17-3-2022, i.e. 30-6-2022-Entitled to benefit of section 115BAA(1) for purpose of computation of income.[S. 139(1),Form No 10-IC]b

S. 115BAA : Tax on income of certain domestic companies-Determination of tax in certain cases-Delay in filing of Form 10-IC-Circular extending the time for filing of return-Eligible for concessional tax rate under section 115BAA.[S. 139(1), Form No. 10-IC]

S. 92CA : Transfer pricing Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Transfer pricing-Reference to TPO-No reference is made to TPO-Addition is deleted. [S.92C]

S. 90 : Double taxation relief-Foreign tax-Non-furnishing of Form No.67 before the due date under section 139(1) is not fatal to claim for foreign tax credit-Assessing Officer is directed to allow foreign tax credit as per Form 67 filed after due verification.[R. 128(9), Form No 67]

S. 90 : Double taxation relief-Foreign tax credit (FTC) cannot be disallowed for delay in filing Form 67 as filing of Form 67 is a directory requirement-DTAA-India-USA [R. 128(9), Art.25]

S. 80P : Co-operative societies-Interest-Investments made in co-operative banks would be eligible for deduction.[S.80P(2)(d)]

S. 90 : Double taxation relief-Foreign tax credit (FTC)-Filed Form No. 67 after due date specified for furnishing return under section 139(1) but before completion of assessment proceedings-Foreign tax credit (FTC) is allowed-DTAA-India-Australia [R. 128, Form No.67, Art. 24]