S. 147 : Reassessment-Income deemed to accrue or arise in India-Interest-Failure to deduct tax deduct at source-Redemption premium paid-Income had not arisen in India in hands of recipient/non-resident and there was no obligation on part of BFL to deduct tax at source on payment of interest-Re assessment is quashed. [S. 5(2), 6, 9(1(vi) 148, 201(IA)]

S. 147 : Reassessment-With in four years-Change of opinion-Scientific research expenditure-No new material-Reassessment is quashed.[S. 35(2AB), 143(3), 148]

S. 145 : Method of accounting-Fall in profit-Detailed explanation is furnished-Estimate profit rate at 4 per cent without rejecting books of account was not in accordance with law.

S. 145 : Method of accounting-Undervaluation of stock-Fall in GP-Allegations made by Special Auditor-Rejection of books of account is unjustified.

S. 144C : Reference to dispute resolution panel-Direction issued by DRP is binding on the Assessing Officer.[S.144C(10)]

S. 144C : Reference to dispute resolution panel-Delay in filing object against draft assessment order-Appeal filed against draft assessment order is not maintainable-No power under section 144C for DRP to condone delay in filing objections either before it or before Assessing Officer. [S. 92CA, 144C(1), 144C(2b)(ii), 144C(3), 253 (1)]

S. 143(2) : Assessment-Notice-Order passed without issuing the notice-Bad in law-Estimate of income is deleted. [S. 148 , 292BB]

S. 115JB : Company-Book profit-Revaluation of lands-Merger-Clause (J) in Explanation 1 to section 115JB(2), would be applicable from assessment year 2013-14 onwards only and thus, Assessing Officer was not correct in invoking clause (J) of Explanation 1 and making adjustments in book profits on account of revaluation of lands in profit and loss account for assessment years 2011-12 and 2012-13.

S. 90 : Double taxation relief-Rate of tax-Dividend Distribution Tax (DTAA)-Refund of DDT paid at a rate exceeding that specified in DTAA-Not justified in claiming beneficial rate on dividends, as specified in Double Taxation Avoidance Agreement-DTAA-India-Denmark-Singapore-[S.115O , art. 10, 11]

S. 90 : Double taxation relief-Foreign tax credit (FTC) cannot be disallowed for delay in filing Form 67 as filing of Form 67 is a directory requirement-DTAA-India-USA. [R. 128(9), Form, 67, Art. 25]