S. 147:Reassessment-Limitation-Non-resident-No reference to TPO-The time-limit for completing the assessment under was available upto 31st March, 2023-Order passed on 8 th January, 2024-Barred by limitation-Additional legal ground on limitation is admitted. [S.92CA, 144C(13), 148 153(2), 153(4), 254(1)]

S.147: Reassessment-After the expiry of four years-Sub-contractors-No failure to disclose material facts-Reassessment order is quashed. [S.148]

S. 143(3): Assessment-limited scrutiny-Profits chargeable to tax-Remission or cessation of trading liability-The addition made under s. 41(1) and disallowance of transmission charges are deleted.[S. 41(1)]

115JB : Company-Book profit-Income from operation of ships-Income offered income under deeming provision-Provsion of book profit is not applicable-DTAA-India Hing Kong. [S. 44B, 90(2), Art. 8]

S.115BAC:Tax on income of individuals and Hindu undivided family-Option-Form No 10E-New regime and old regime-The assessee cannot be forced to adopt the new regime-The action of the CPC in processing the return of income determining the total income under the new regime of taxation is quashed and set aside.[S. 139, Form No.10E]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Interest on outstanding receivables from AES-Outstanding dues beyond an agreed credit period are separate international transaction, which requires to be benchmarked separately and cannot be clubbed together with other transactions-Working capital adjustment subsumed accrued interest on trade receivables, and no separate adjustment should be made was not advanced before the TPO or the DRP-, Issue is restored back to the TPO.[R. 10A]

S. 69A : Unexplained money-Income Declaration Scheme, 2016-quoted wrong PAN No.-issue is restored to the AO for necessary verification. [Income Declaration Scheme, 2016]

S. 69 :Unexplained investments-Jewellley-Banl locker-Old jewellery was converted in to bullion-Addition is justified. [S. 132, 153A]

S. 68 : Cash credits-Repayment of loan-Addition is deleted-Loan outstanding-Report of the Inspector is not provided to the assessee-Violation of principle of natural justice-The matter is restored to the AO to provide the report of the Inspector to the assessee for his rebuttal with proper and supporting evidences.[S. 133(6)]

S. 68 : Cash credits-Survey-Disclosure of additional income as business income-Surrendered income cannot be assesses as cash credit and invoking the provision of section 115BBE of the Act. [S. 115BBE, 133A]