S. 153A: Assessment-Search-Undisclosed income-Manufacturing facility of the assessee does not make it feasible for packaging of the products in small packets-First appellate authority has rightly appreciated the veracity of the evidence furnished by the assessee after verification-Input-output ratio-Order of CIT(A) was affirmed.[S. 132]

S. 153A: Assessment-Search-Undisclosed income-The assessee received software services, and the consideration paid for such services cannot be disallowed. [S. 37]

S. 147: Reassessment-Search-Incriminating documents-Notice issued on the basis of documents seized from a third party not pertaining to the assessee-Reassessment was quashed. [S. 69, 148, 153C]

S. 144C: Reference to dispute resolution panel-Direction of DRP-Final assessment order not in conformity with the directions of DRP-The assessment order is quashed-Non-service of order is not invalid.[S.80IA, 144C (13)]

S. 143(3): Assessment-Non-existing entity-Intimated the AO of the merger-Prior to the insertion of S. 170A w.e.f. 1st April, 2022, there was no provision enabling the filing of a modified return-The order passed by the AO is void ab initio. [S.170A]

S.143(3): Assessment-Limitation-Generation of multiple DINs by AO-Not barred by limitation.[S.153]

S. 143(2): Assessment-Notice –No evidence on record regarding any order of transfer under S. 127-The assessment framed by ITO-3(4), Raipur vide his order passed under s. 143(3) in the absence of an order of transfer under S. 127 without issuance of any notice by him under s. 143(2) to the assessee, is without valid jurisdiction, was bad in law; hence quashed. [S.124(3)(a), 127, 143(3)]

S. 115-O: Domestic companies-Tax on distributed profits-Refund-Entitlement-Refund of Dividend Distribution Tax paid on dividend to International Finance Corporation-Entitled to refund. [IFC Act, 1958]

S. 115A: Foreign companies-Tax on interest income-Interest on compulsory convertible debentures and optionally convertible debentures-Entitled to concessional rate under S. 115A(1)(a)(BA)(ii) r/w s. 194LD in respect of OCDs and CCDs [S. 115A(1)(a)(BA)(ii), 194LD]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Notional interest on receivables due from AE-Outstanding receivables from AE are an international transaction-LIBOR being the internationally accepted rate of interest for benchmarking, LIBOR plus 200 basis points should be adopted for imputing interest on overdue receivables.[S.92B]