S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Principle of natural justice-Sufficient opportunity to be heard is not given-Order is not valid [S. 147, 148, 148A(b), 148A(d), Art. 226]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment is not valid. [S. 148, Art. 226]

S. 145 : Method of accounting-Rejection of accounts-Rule of consistency-Offering income to tax in year in which services rendered-Tax rate same and no loss to revenue-Rejection of books of account is not justified. [S. 260A]

S. 143(3): Assessment-Natural justice-24 hours time to respond notice-No adequate opportunity to respond to notice-Assessment order is quashed and set aside-Matter remanded. [S. 144B, Art. 226]

S. 139 : Return of income-Delay in filing return-Limitation-Delay of five months-CBDT-Period to be computed with reference to date on which return had been filed [S.119(2)(b), Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-
International transaction-Comparable-Advertisement and marketing-No substantial question of law. [S.92CA, 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-No substantial question of law.[S.260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Determination of Arm’s Length Price based on examination of entire material on record-No question of law.[S. 260A]

S. 68 : Cash credits-Not explained the source-Addition is justified.[S. 260A]