S. 144C : Reference to dispute resolution panel-Rectification order-Not barred by limitation-Order was passed within six months from end of month in which original order was passed-It would not be open to Assessing Officer to hold giving effect to these directions even if said directions were found to be prima facie incorrect. [S. 92C,144C(13), R. 10]

S. 144C : Reference to dispute resolution panel-Rectification application-Rule 13 does not permit a rectification application being entertained from a person other than assessee, Assessing Officer or DRP itself-Miscellaneous application filed by TPO before DRP for rectifying various mistakes in order of DRP would not be maintainable.[S.92C, 154, Rule 13]

S. 144C : Reference to dispute resolution panel-Limitation-Time-limit for passing final order of assessment-One month from end of month in which directions of Dispute Resolution Panel received by Assessing Officer-Order passed beyond that date-Non est in law. [S. 92CA (3), 144C(13), 153, 153B]

S. 144C : Reference to dispute resolution panel-Arm’s length price-Transfer pricing adjustment was not in accordance with the direction of the Dispute Resolution Panel-Order was quashed. [S. 144C(13)]

S. 144C : Reference to dispute resolution panel-Capital gains-Non-Resident-Eligible assessee-Change Of Law-Amendment to include non-Residents as eligible assessees with effect from 1-4-2020-Pending assessments for which orders passed after 1-4-2020 is covered by amended section.[S. 45, 49]

S. 144C : Reference to dispute resolution panel-Draft assessment order-Assignment of finality to draft order-Order vitiated. [S. 143(3)]

S. 144C : Reference to dispute resolution panel-Order not in conformity with directions of Dispute Resolution Panel-Order bad in law and not sustainable. [S. 143(3)]

S. 144C : Reference to dispute resolution panel-Transfer pricing-Assessing Officer to pass final order from end of month in which direction received from Dispute Resolution Panel-Order not barred by limitation.[S. 92C, 144C(13)]

S. 144 : Best judgment assessment-Cash deposited in assessee’s Bank Account-Burden of proof on assessee that bank account not his-Matter remanded for adjudication afresh. [S. 143(3)]

S. 144 : Best judgement assessment-Income from undisclosed sources-Estimation of profits-Profits declared at 14.80%-Amount deposited in account much higher than turnover-Assessing officer applied net profit at 8%-Additions justified-Interest income not disclosed-Addition is justified. [S. 69, Form 26AS]