S. 147 : Reassessment-After the expiry of four years-Failed to electronically upload Form 10CCB along with return of income within the timeframe prescribed under section 139-Reassessment notice and order disposing the objection were quashed and set aside. [S. 80IA(7), 139, 148, Form 10CCB, R.12, Art. 226]

S. 145 : Method of accounting-Solicitor-Client’s money-Amounts received by solicitor from clients for specific tasks-Amounts received in fiduciary capacity-Not assessable as income. [S.4, 260A]

S. 144B : Faceless Assessment-Subsequent notice indicating the Department’s intention to make assessment in a faceless manner and requiring the assessee to file a reply on the online portal rather than to the jurisdictional AO-Notice need not be interfered with. [S. 147, 148, 151(1), Art. 226]

S. 143(3) : Assessment-Jurisdiction to assess-Formation of Centralised Processing Centre-CPC acts as facilitator and does not take away jurisdiction of Assessing Officer under section 120. [S. 120, 143(1A), 154, 263, 264, Art. 226]

S. 143(3): Assessment-Pendency of appeal-Writ-Alternative remedy-Suppressing material information of filing of statutory appeal-Pursuing parallel remedies amounted to treating extraordinary remedy as an alternate remedy to appellate remedy-Petition dismissed and cost of Rs. 1 lakh was imposed to be paid to the High Court Employees Medical Welfare Fund at Mumbai. [S. 246A, Art, 226]

S. 132 : Search and seizure –Stock in trade-Burden of proving goods constituted stock-in-trade of business, lies on assessee.[S. 131(IA), 132(1)(iii),132(4) Art. 226]

S. 132 : Search and seizure-Satisfaction note-Reasons recorded-Non-compliance with statutory requirements under section 132(1) vitiated search and seizure operations. [S. 132(1), Art. 226]

S. 127 : Power to transfer cases-Denial of reasonable time to respond to notice-Matter remitted to Principal Commissioner to afford personal hearing to assessee and decide in accordance with law.[Art.226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Disallowance of expenditure-Existence of international transaction must be established and not inferred-Burden on Revenue to prove existence of international transaction-Amendment introducing deeming fiction in section 92B(2) with effect from 1-4-2015 not applicable to assessment years 2009-2010 and 2012-2013-Orders of assessment set aside. [S. 92B, 92CA, 92D, 92F, 260A]

S.80IA: Industrial undertakings-Enterprises engaged in infrastructure development-Contractor or developer-Road project-No substantial question of law.[S.80IA(4)]