S. 147 : Reassessment-Search and seizure-Reassessment-Assessment of third person-Notice opportunity of hearing not mandatory for issue of notice of reassessment pursuant to search-Satisfaction note is internal communication of Department not requiring document identification number-No provision requiring supply of copy of satisfaction note to assessee with notice for reopening assessment – SLP against High Court order dismissed. [S. 132, 148, 153A Art.136]

S. 147 : Reassessment-Capital gains-Information from investigation unit – Penny stock – Borrowed satisfaction- Fishing inquiry not permissible – Order of High Court quashing the notice is affirmed – SLP of revenue dismissed.[S. 10(38), 45, 148, Art. 136]

S. 145 : Method of accounting-Business income-Valuation of closing stock-Consistent application of cost or net realisable value method – Order of Tribunal deleting the addition is affirmed. [S.28(i)]

S. 143(3): Assessment- Excess stock – Violation of principle of natural justice – Order of assessment was quashed and set aside-Existence of alternate remedy-Not an absolute bar for issue of writ Violation of principles of natural justice. [S.69B, Art. 226]

S. 143(3): Assessment-Jurisdiction-Transfer of case-Notice issued by Assessing Officer from whose jurisdiction case was transferred-Notice not valid.[S. 260A, 263]

S. 143(3): Assessment-Failure of assessee to update e-mail ID resulting in non-receipt of-Own fault- No violation of principles of natural justice-Order valid- Given liberty to file statutory appeal. [S. 144B, 246A, Art. 226]

S. 132 : Search and seizure-Reasonable belief- All three conditions must be satisfied-Satisfaction note – Failure to disclose capital gains–Absence of jurisdictional pre-requisites for exercise of power under section 132 Search and seizure illegal Revenue granted liberty to initiate reassessment proceedings in accordance with law–Warrant of authorisation quashed and subsequent search and seizure illegal-Competent authority not empowered to issue notice under section 131 (1) after initiation of search and seizure under section 132(1) Notice issued after search and seizure unsustainable-Interpretation of taxing statutes Strict interpretation and compliance.[S 45, 55(2)(ac), 131(1), 132, 147, 148, Art. 226]

S. 127 : Power to transfer cases-Facilitate co-ordinated investigation of cases-Order of transfer was valid.[Art. 126]

S. 115JB : Company-Book profit -Expenditure towards corporate social responsibility-No basis for excluding expenditure on corporate social responsibility for determining book profits-Book profits to be determined as per accounts maintained in accordance with law Income-tax Act.

S. 92C : Transfer pricing – Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Entertainment business- Royalty Payment-Transfer Pricing Officer cannot examine commercial expediency. Royalty payable under licence agreement. No question of law arose regarding disallowance on account of royalty paid by assessee to associated enterprises. Order of Tribunal affirmed. [S. 9(1)(vi), 260A]