S. 143(1): Assessment-Intimation-Employees’ contribution to Provident Fund and ESI-Delay in deposit-Adjustment while processing return under section 143(1)-Valid-Processing of return-Intimation dated 31-3-2021 communicated by e-mail on 1-4-2021-Not barred by limitation-Prima facie adjustment-Incorrect claim apparent from return-Adjustment based on tax audit report-Valid-Prima facie adjustment-Prior intimation through e-mail-Compliance with principles of natural justice. [S. 36(1)(va), 143(1)(a)]

S. 115JB: Company-Book profit-Minimum Alternate Tax-Book profit-Sales tax subsidy-Capital receipt-Subsidy reduced from written-down value of assets-Not includible in book profit. [S.2(24)(xviii)]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Captive software development services-Business closed after expiry of service agreement-Adjustment cannot be made on expenses incurred for closure of operations-Notional income not taxable.[S.92CA]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Advertisement, Marketing and Promotion (AMP) expenditure-Revenue failed to establish existence of international transaction-No transfer pricing adjustment-Information Technology support services-Separate international transaction-Matter remanded for fresh benchmarking.[S.92, 92B,92CA, 92F]

S. 69A: Unexplained money-Cash deposits during demonetisation-Cash generated from additional income disclosed before Settlement Commission-Source explained-Addition deleted.

S. 69A: Unexplained money-Search assessment-Financial broker-Cash loans belonging to clients-Brokerage income already disclosed-Addition as unexplained money deleted-Seized document-Entire document to be read as a whole-Revenue cannot rely selectively on favourable entries.[S.69A, 132, 132(4), 153C]

S. 68: Cash credits-Loans received by non-banking financial company-Identity, creditworthiness and genuineness established-Running account between parties-Addition deleted.

S. 68: Cash credits-Share capital and share premium-Identity, creditworthiness and genuineness established-No incriminating material found during search-Addition deleted.[S. 132]

S. 68: Cash credits-Loan repaid through account payee cheques-Documentary evidence ignored-Addition deleted-Unexplained investment-Purchase of immovable property-Source partly explained-Addition restricted.[S.69]

S. 68: Cash credits-Unsecured loans-Repayment through banking channels accepted in subsequent year-Addition of loans, commission and interest deleted.