S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Natural justice-Period granted was less than seven days-Responded the notice-Amount in dispute less than 50 lakhs-Notice issued beyond three years-Notice and order was quashed and set aside. [S. 148, 148A(d), 149(1)(b), Art. 226]

S. 147 : Reassessment-Order disposing the objection must be reasoned order-If the assessing Officer is going to rely on any order or Judgment of any court or Tribunal a list thereof shall also be provided to Petitioner along with a notice for personal hearing so that Petitioner can deal with/distinguish those Judgments during personal hearing-Order disposing the objection was quashed-Directed to pass speaking order giving an opportunity of personal hearing [S. 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Franchise fee-Capital or revenue-No failure to disclose material facts-Specific query in the course of original assessment proceedings-Reassessment notice and order disposing the objection was quashed. [S. 37(1), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-No new information-Reassessment notice and order disposing objection was quashed. [S. 80IA, 148, Art. 226]

S. 147 : Reassessment-After expiry of four years-Capital gains-No failure to disclose material facts-Reassessment notice and order disposing the objection was quashed. [S. 2(47)(v), 45, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Estimate of gross profit-Reassessment notice to make addition of 5 percent of turnover instead of 1 percent addition was made in scrutiny assessment-Change of opinion-Notice and order disposing the objection was quashed. [S. 148, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-An investment advisor or sub-advisory cannot be compared with a merchant banker or investment banker-Tribunal’s finding based on decision of Supreme Court-No question of law. [S. 260A]

S. 69C : Unexplained expenditure-Bogus purchases-Accommodation entries-Civil contract work-Municipal Corporation of greater Mumbai-Information received from the Sales Tax Department through the Director General (Inv)-Purchases through banking channels-Disallowance restricted to profit element-Order of Tribunal affirmed. [S. 143(3), 260A]

S. 10B : Export oriented undertakings-Deduction and not exemption-Set off of losses-Loss from export oriented undertakings-Can be set off against other business income-Payment of management fees-Transfer pricing adjustment-Closing stock addition-Provision for absolute inventory-Valuation of stock on scientific basis-Question of fact. [S. 70, 71, , 92C,260A]

S. 4 : Charge of income-tax-Loss of source of income-The amount received under the deed for restrictive covenant as a capital receipt not liable to tax. [S. 7(1)(iv), 17(3)(i), 28(va), Art. 226]