S. 147 : Reassessment-Business income-Value of any benefit or perquisite, arising from exercise of business or profession-Merger-Demerger-Transfer of Passive Infrastructure Assets (PIA) to ICTIL and subsequent amalgamation into Indus Towers, and demerger of telecom undertaking of ABTL-Scheme approved by High Court-No colourable device-Provision of section 28 (iv) cannot be applied-Non-compete fee-Change of opinion-amount debited in P&L Account as Employees Stock Scheme had been disallowed as being a contingent liability-Change of opinion-Reassessment is not valid.[ S.28(iv), 37(1), 1115JB,148]

S. 145 : Method of accounting-Unaccounted stock-Cash found during survey-Books of account was not complete-Justified in rejecting the books of account-Bogus purchases-Restricted the disallowance to 6% of bogus purchases as against 12.5% estimated by the CIT(A). [S. 133A, 145 (3)]

S. 144C : Reference to dispute resolution panel-Limitation-Order is barred by limitation.[ S.92CA (3A), 143(3) 153 (1), 153(4)]

S. 144C : Reference to dispute resolution panel-Limitation-Order is barred by limitation.[ S.92CA (3A), 143(3) 153]

S. 143(3): Assessment-Return-Refund-Amalgamation-Non-existent entity-Credit for taxes paid-Assessing Officer is bound to give credit of taxes paid under section 199 and allow refund of tax in accordance with law. [ S.139, 139(9) 199, 237]

S. 143(3): Assessment-Final assessment order is passed-Assessing Officer had no powers to either withdraw or modify or substitute assessment order passed under section 143(3) with another assessment order. [ S. 144C]

S. 143(3): Assessment-Limited scrutiny-Unsecured loan-Notice beyond scope of limited scrutiny-CBDT Instruction No. 5/2016, dated 14-7-2016-Assessment is bad in law. [ S. 36(1)(iii), 37(1), 68, 119]

S. 143(3): Assessment-Document Identification Number (DIN)-Assessment order without obtaining Document Identification Number (DIN) is invalid-No jurisdiction-Order passed without issuing the notice u/s 143(2)-Order is quashed.[ S.143(2), 144, 147]

S. 142(2A) : Inquiry before assessment-Special audit-Additional ground is admitted-Order is barred by limitation.[ S. 153B, 254(1)

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Purchase of shares from Associated Enterprise-DCF method-Adjustment is deleted-Transactions under taken by the promoters / share holders of the company-Sale of shares using CUP method-Gap of three months-Matter remanded to the TPO.[ R. 10B(5)]