S. 143(3) : Assessment-Reassessment-After the expiry of four years-Unexplained money-search-Cash payment-Peak amount-Unaccounted investment-Alternative remedy-Writ petition is dismissed.[S. 69A. 115BBE, 143(3), 147, 148, Art. 226]

S. 139A : Permanent account number-Same number is allotted to another person-Income-tax Department was to be directed to forward a letter to CIBIL/other credit information companies informing about issuance of same PAN to assessee as well as to other person. [Art. 226]

S. 132 : Search and seizure-Satisfaction note did not disclose any information which the authorities to have reason to believe were satisfied-Search and seizure action is quashed-Revenue may utlise the information or material in such proceedings as they may be so advised and to utilise the information or material in such proceeding against the assesse as is permissible in law. [S. 132(1)(a) to (c), Art. 226]

S. 132 : Search and seizure-Freezing bank accounts-As per section 132(8-A), order of freezing bank accounts could not remain in force for a period exceeding sixty days from date of order.[S. 132(3), 132(8A), Art. 226]

S. 120 : Jurisdiction-Search and seizure-Third party-Not connected with the assessee-No cause of action-Writ petition is dismissed. [Art. 226]

S. 119 : Central Board of Direct Taxes-Instructions-Return-Condonation of delay-Illness of accountant-Reasonable cause-Genuine hardship-Delay is condoned-Order of CBDT is set aside-Directed to file the return within 15 days. [S.119(2)(b), 139 (1), 139(4), Art. 226]

S.119 : Central Board of Direct Taxes-Instructions-Circular-Tax on income of new manufacturing domestic companies-Application for condonation of delay-Relied on report which is not made available to the petitioner-Order is not passed or signed by the Member who has given personal hearing-Principles of natural justice would require that revenue should have made available a copy of report received by them from Field Authorities to assessee and given them an opportunity to explain or show cause-Matter remanded to Central Board of Direct Taxes with directions. [S. 115BAB, 119 (2)(b), Form No 10-ID, Art. 226]

S. 115JB : Book profit-Disallowance made under section 14A could not be considered for computing MAT.[S. 14A, R.8D]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-
International transaction-Written Down Value of assets as may be reflected in books would not be liable to be taken into consideration while answering issue of ALP-No substantial question of law. [S. 260A, R.10B]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax- International transaction-AMP expenses-High Court held that approach of TPO of determining ALP of such AMP expenditure either on BLT bases or TNMM could not be sustained-SLP is granted to the Revenue. [S.92B, Art. 136]