S. 144B : Faceless Assessment-Prior to 1-4-2021-Order passed without notice-cum-Draft assessment order-No opportunity of hearing-Order of assessment was not valid-High Court-Territorial Jurisdiction-Part of cause of action arising in a particular area-High Court of that area has jurisdiction. [S. 143(3), Art. 226]

S. 132(4) : Search and seizure-Statement on oath-Income from undisclosed sources-Income surrendered during search-Retraction of statement after eight months-Statement cannot be discarded. [S. 131, 132, Art. 136]

S. 132 : Search and seizure-Release of seized documents-Directions issued for the release of documents pertaining to assessee. [Art. 226]

S. 115JB : Book profit-Banking company-Provision is not applicable.

S. 92C : Transfer pricing-Arm’s length price-No international transaction between assessee and its associated enterprises-Band promotion-Advertisement, marketing and promotion-Deletion of disallowance is justified. [S. 37(1), 92]

S. 92C : Transfer pricing-Arm’s length price-Advertisement, market and business promotion expenses-Not international transaction-No change of facts-Res Judicata-Principle of consistency must be followed. [S. 92B]

S. 92B : Transfer pricing-Arm’s length price-Corporate guarantee-Tribunal remanding matter to Assessing Officer for de novo adjudication-Need not be interfered with.

S. 92B : Transfer pricing-International Transactions-Provision of corporate guarantee-Loan Advanced to Associated Enterprise-Tribunal remanded the matter to Commissioner (Appeals)-Order of Tribunal affirmed by High court-SLP of Assessee is dismissed. [Art. 136]

S. 92 : Transfer pricing-Arm’s length price-Management services, management information services, information resources and system development-Reimbursement of expenses-Order of Tribunal affirmed-DTAA-India-USA. [S. 260A, Art. 12(4)(b)]

S. 90 : Double taxation relief-Agreement-Taxing receipts-Question of fact-No substantial question of law-DTAA-India-USA. [Art. 12, 260A]