S. 151 : Reassessment-Sanction for issue of notice-Search cases-Search assessment-Approval by Director General having jurisdiction over Central Charge-Sanction valid.-CBDT Notification No. 68 of 2014, dated 13-11-2014-Escaped income represented by asset exceeding Rs. 50 lakhs-Reopening not barred by limitation-Central Charge-Assignment outside faceless assessment scheme-Jurisdictional Assessing Officer competent to complete assessment-Seized diaries-Statement under section 132(4) admitting ownership-Subsequent plea that diaries belonged to family members rejected-Seized diaries-Tally books subsequently prepared not reliable-Profit to be determined from seized diaries-Land trading-Estimation of profit-Profit rate of 13.14 per cent. held reasonable-Share trading-Estimation of profit-Profit rate of 8 per cent. on total credits directed-Trading account (Maal Khaate)-Income estimated at 10 per cent. of total credits–Peak credit-Telescoping of income assessed in earlier years-Benefit allowable-Bad debts-Claim not reflected in seized diaries-Deduction not allowable–Accrued interest-Notional entries in seized diaries-Double taxation avoided-Addition deleted-Negative peak cash balance-Opening balances of earlier years to be considered-Matter restored-Miscellaneous cash transactions-Only undisclosed income taxable-Peak credit method upheld. [S.28(i), 36(1)(vii), 44AB,44AD, 69, 69A, 115BBE, 132, 132(4), 147, 148, 149(1)b), 153A]

S. 147 : Reassessment-Change of opinion-Reinsurance premium paid to non-resident reinsurers-No fresh tangible material-Reopening invalid.[S. 40(a)(i),148, 195]

S. 147 : Reassessment-After the expiry of four years-Disallowance under section 14A already deleted in assessee’s own case-No failure to disclose material facts-Reassessment invalid-Speculative transactions-No addition made on issue forming basis of reopening-Addition on other issues not permissible-Reassessment invalid. [S.14A,40A(2)(b), 43(5), 73 148, R. 8D]

S. 145: Method of accounting-Business expenditure-Real estate developer-Project completion method-Percentage completion method-Consistent method of accounting accepted in earlier year-No justification to change method-Addition deleted.[S. 28(i),37(1), Accounting Standard-9.]

S. 145 : Method of accounting-Change in accounting policy for long-term insurance policies-Deferred recognition of premium-Addition upheld.

S. 144C : Reference to dispute resolution panel-Assessment-Directions of Dispute Resolution Panel-Final assessment order passed beyond statutory time-limit-Order barred by limitation and void.[S. 144B, 144C(5), 144C(13)]

S. 143(2) : Assessment-Notice-First notice returned unserved-Second notice issued beyond limitation-No valid service within prescribed time-Assessment without jurisdiction.[S. 143(3)]

S. 115JB : Company-Book profit-Insurance company-Reserve for unexpired risks and premium deficiency-No adjustment permissible under Explanation 1-Addition deleted.

S. 92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-Captive power plant-Transfer pricing-State Electricity Board tariff not comparable-Arm’s Length Price to be determined on internal comparable-Eligible business-Non-claim of deduction under section 80-IA-Does not exclude applicability of section 92BA.[S.80IA(8), 80IA(10), 80IB 92CA, R. 10B]

S. 90 : Double taxation relief-Non-resident-Delaware Limited Liability Company-Fiscally transparent entity-Liable to tax in USA-Treaty benefits available-DTAA-India-USA.