S. 119 : Central Board of Direct Taxes-Refund-Condonation of delay-Delay in filing of return-PCIT has no power to consider the merits of the refund application and what is required to be considered is the merits of the application for condonation of delay only-Matter is remitted back for reconsideration. [S. 119(2(b), 139, 237, 240, Art. 226]

S. 115BBE : Tax on specified income-Determination of tax in certain cases-Reassessment-Limitation-Alternative remedy-Act provides complete machinery for assessment/reassessment of tax and the assessee is not permitted to abandon that machinery to invoke jurisdiction of the High Court under Art. 226 of the Constitution-S. 115BBE cannot be held unconstitutional on the ground that there an apprehension of misuse of the said provision. [S. 68, 148, 148A, 149, Art. 14, 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Net Margin Method-Advertisement, marketing and promotion expenses-Comparison-Application of BLT tool was wrong-No substantial question of law.[S. 260A]

S. 80JJAA : Employment of new workmen-Period of 300 days can be taken in to consideration both in the previous and succeeding years-It is not required that workmen work for 300 days in previous year relevant to assessment year-Appeal of assessee is allowed.[S. 260A]

S. 68 : Cash credits-Agriculturist-Cash deposit in foreign bank in Geneva-Bank account belonged to his nephew residing in U.K-Deletion of addition is affirmed.[S. 69, 260A]

S. 40A(3) : Expenses or payments not deductible-Cash payments exceeding prescribed limits-Purchases of amount exceeding Rs. 20, 000, on a single day-Failure to produce bills-Disallowance made by Assessing Officer of 20 per cent of cash payments is affirmed. [R. 6DD, 260A]

S. 4 : Charge of income-tax-Exemption from payment of tax under exemption certificate issued under section 4A of on turnover of sales-Not subsidy-Assessable as revenue receipt. [S. U.P. Trade Tax Act, 1948, S.4A]

Prohibition of Benami Property Transactions Act, 1988
S. 24(1): Benami Transactions-Attachment of property-Satisfaction of initiating Officer that person in possession of property held benami may alienate property during period specified in notice-No material in possession of initiating officer, to show property held benami is likely to be sold-Attachment order is set aside. [S.2(8), 2(9), 24(3), Art. 226]

S. 276 : Offences and prosecutions-Wilful attempt to evade tax-Under reporting of income-Search-Settlement Commission-Pending criminal prosecution is not brought to knowledge of Settlement Commission-Immunity against prosecution granted by Settlement Commission without knowledge of pending prosecution-Provisions of Section 245I is not applicable-Prosecution cannot be quashed. [S. 132, 245C, 245H(1), 245-I, 277, Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Long term capital gain-Order not prejudicial to interests of Revenue-Revision is not sustainable.[S. 10(38), 45, 260A]