S. 145 : Method of accounting-Scrap sale-Estimation of profit-Survey-Not able to reconcile-Addition is held to be justified. [S.133A]

S. 144C : Reference to dispute resolution panel-Period of limitation has to be strictly followed-Order passed beyond period of limitation prescribed under section 144C(4)(b) of the Act is declared invalid. [S. 144C(4)(b)]

S. 144C : Reference to dispute resolution panel-Condonation of delay-DRP does not have power to condone delay in filing objections by assessee before Panel.

S. 143(3) : Assessment-Protective assessment-Income from other sources-No substantive addition was made in the other party-Addition was deleted. [S. 56]

S. 143(3) : Assessment-No direction of Appellate Tribunal to do fresh assessment-Passing remark by the Appellate Tribunal cannot be considered as observation of the Appellate Tribunal. [S. 254(1)]

S. 120 : Jurisdiction of income-tax authorities-Returned income less than of 30 lakhs-Jurisdiction of Assessing Officer-Assessment made by the Assistant Commissioner is without jurisdiction-Bad in law. [S. 127(1), 143(2), 143(3)]

S. 92C : Transfer pricing-Arm’s length price-Abnormal events-If an extraordinary event has taken place by way of amalgamation in a company, that company cannot be considered as a comparable-.R-elated party transaction of selected company exceeded limit of 25 per cent, said company be excluded from comparable list-turnover of selected company was almost 80 times more than turnover of assessee-company, said company could not be selected as comparable.

S. 92C : Transfer pricing-Arm’s length price-High Turnover-Huge intangible addition-Negative working capital-High turnover is a ground for excluding companies as not comparable with a company that has low turnover-Huge intangible assets-Could not be considered for inclusion in list of comparables to software development services provider.-Negative working capital adjustment shall not be made in case of a captive service provider as there is no risk and it is compensated on a total cost plus basis.

S. 92C : Transfer pricing-Arm’s length price-Turnover-Comparable-Companies having turnover of more than 200 crores upto 500 crores have to be regarded as one category and said companies cannot be regarded as comparables with companies having turnover of less than 200 crores.

S. 92BA : Transfer pricing-Specified domestic transactions-Interpretation-Omission of provision-Clause (i) of section 92BA being omitted by Finance Act, 2017 w.e.f. 1-4-2017 from statute, could not be made applicable in pending proceeding of assessee, and therefore, impugned order passed by TPO invoking such section 92BA(i) was without any basis and bad in law, thus, was liable to be quashed. [S. 40A(2)]