S. 147: Reassessment-Report of Investigation Wing-No tangible material-Reassessment is bad in law-Cash credits-Identity and creditworthiness is established-Addition is deleted. [S.68 148]

S. 147: Reassessment-Survey-Facilitating dubious transactions by accepting huge cash deposits from suspicious/unidentified entities and thereafter transferred most of these amounts to various other suspicious entities-Reassessment notice is valid.[S.133A, 148]

S: 145: Method of accounting-Project completion method-Advance from customers-Sale of 54 units-Neither sales were effected nor the possession of the flats were handed over to the purchasers during the relevant year-CIT(A) was not justified in sustaining the ad hoc addition of 10 per cent of the agreed value of the flats and also ad-hoc disallowance of common expenses. [S. 4, 37(1)]

S. 143(1) : Assessment-Intimation-Prima facie adjustment-Inclusion of excise duty in the turnover for determining rate of tax-The adjustment made while processing the return is not sustainable. [S. 44AB,143(1)(a), 145A]

S. 115JB : Company-Book profit-The provision of S. 115JB is not applicable to Banking companies.[The Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970, S. 11, Companies Act, 2013, S.3, 129]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on receivables-Interest on outstanding receivables from AE-International transaction-60 days and 240 days-The arm’s length interest rate on similar foreign currency receivables/advances is to be taken as LIBOR+200 points. [S.92B]

S. 90 : Double taxation relief-Salary received-Services rendered in Australia-Not taxable in India-DTAA-India-Australia. [S.5, 9(1)(ii) 15, Art. 4(1), 15(1)]

S. 90 :Double taxation relief-Capital gains-Tax residency certificate-Eligible for the benefits of the DTAA in respect of capital gain on the sale of shares of an Indian company and the interest income from compulsorily convertible debentures-DTAA-India-Singapore. [Art. 11, 13]

S. 90 :Double taxation relief-Fees for included services-Support services to achieve standardized IT environment-The amount received by the assessee on account of said services does not fall within the ambit of ‘fee for included services-Not taxable in India DTAA-India-Singapore. [S. 9(1)(vi),9(1)(vii), Art. 12]

S. 80P : Co-operative societies-Providing credit facilities to members-Interest received from members and non-members-Mutuality-If the nominal/associate members of the assessee society are not members and they are not entitled to share of profits earned by the assessee, then proportionate deduction under s. 80P(2)(a)(i) is to be granted in respect of interest earned by providing credit facilities only to the regular members; issue is remitted to the AO for afresh consideration.[S.57(iii), 80P(2)(a)(i), 80P(2)(d)]