S. 147 : Reassessment-With in four years-No specific query was raised in the course of original assessment on which the reassessment is initiated-Reassessment is valid-Electrical installations-Entitle to depreciation at 15%-On merits additions are set aside to the file of Assessing Officer. [S. 2(47), 14A, 32, 40(a)(i), 148]

S. 147 : Reassessment-No addition is made on the basis of recorded reasons-Reassessment is bad in law-The AO lacks jurisdiction to make independent addition-Limited scrutiny-Not obtaining approval for converting limited scrutiny in to complete scrutiny-Order is not valid. [S. 2(22)(e), 143(3), 148]

S.147: Reassessment-After the expiry of four years-Cash credits-Accommodation entries-Objection is not disposed-Information from ADGIT Investigation (OSD)-The addition made without enquiry and without application of mind-Reassessment is quashed. [S.143(1) 148]

S. 145 : Method of accounting-Books of account-Rejection of estimation of profits-Rejection of books of account is held to be not justified. [S. 44AB, 145(3)]

S. 144C : Reference to dispute resolution panel-Not an eligible assessee-Assessment-Limitation-Assessment order is bad in law-Additional ground is allowed.[S.92CA(3A), 144C(15)(b), 153 (4) 254(1)]

S. 132: Search and seizure-undisclosed income-bogus purchases-failure to rebut statement of the broker by documentary evidence by the Assessee, restricting addition to 12.5 percent is held to be proper [S. 132]

S. 115BBE-Tax on specified income-Determination of tax in certain cases-Unaccounted stock declared during survey-Excess stock being part of total business stock-Cannot be assessed as deemed income [S.69, 69B]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Persistent Loss Filter-Matter remanded-Turnover filter-Companies whose turnover in current year is more than Rs. 200 crores is to be excluded from list of comparables-Companies Lacking Segmental Information And Functionally Dissimilar with assessee cannot be taken as comparables-Interest on outstanding receivables-Matter remanded-Rate of interest charged at Libor + 300 basis points considering credit period of 90 days.[S.92B, 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Turnover filter-Companies having turnover exceeding two hundred crore rupees were to be rejected-Persistent losses filter-Matter remanded-Notional interest on overdue receivables-Transfer Pricing Officer to recompute adjustment only in respect of invoices overdue for more than ninety days at interest rate of six months, Libor plus three hundred and fifty basis points.[R. 10B]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Selection of comparable-Matter remanded. [R.10B]