S. 153C: Assessment-Income of any other person -Search-A satisfaction note is required to be recorded under section 153C for each assessment year-A consolidated satisfaction note recorded for different assessment years would vitiate entire assessment proceedings [S. 132, 153A]
S. 147: Reassessment -“Reason to believe” -Reopening invalid where reasons recorded are factually incorrect and based on non-application of mind-Assessment was quashed. [S. 148, 151]
S. 147: Reassessment -Addition cannot be made on issues unconnected with reasons recorded for reopening. Addition was deleted. [S. 148]
S. 147: Reassessment -Additional ground-Reassessment proceedings initiated solely on the basis of NMS, without any independent verification, tangible material, or proper satisfaction recorded by the AO, would not confer valid jurisdiction under section 147-Initiation of reassessment proceedings under section 147 was void ab initio. [S. 115A, 139, 148, 194LD, 254(1)]
S. 147: Reassessment-Validity of addition on new issue -Assessment reopened for escapement of salary income, but addition made on account of Recurring Deposit Investment -Addition was deleted. [S. 148]
S. 145 : Method of accounting-Revenue recognition -Derecognition of income in books -Addition sustainable. [S.28(i)]
S. 144C: Reference to dispute resolution panel Reassessment -Limitation -Non-resident-Extended limitation under S. 153(4) available only where reference is made to Transfer Pricing Officer -Reassessment beyond prescribed period invalid. (S. 92CA, 144C, 148, 153(2), 153(4)
S. 143(1): Assessment -Intimation-Issue of notice -Denial of exemption-No adjustment shall be made unless prior intimation of the proposed adjustment is given to the assessee-Matter restored to CIT(A). [S. 11(1)(d),12A, 143(1)(a)]
S. 92C : Transfer pricing -Arm’s length price-Avoidance of tax-International transaction-Selection of comparables -Companies engaged in diversified activities without segmental results-Functionally not comparable –Addition was deleted. [S.92CA]
S. 92C: Transfer pricing -Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-No estoppel-Assessee is not estopped from seeking exclusion of company originally selected in TP study.[S.92CA]