S. 147 : Reassessment-After the expiry of four years-Accommodation entries-Facts disclosed in the original assessment proceedings were false-Notice is held to be valid [S.148, Art, 226]

S. 147 : Reassessment-After the expiry of four years-Report of investigation wing-Non application of mind by the Assessing Officer-Notice not valid. [S. 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Arm’s length price-Objection considered by the Dispute Resolution panel-Alternative remedy-Every error of an authority is not open to judicial review merely by terming it a “jurisdictional error”, although it may, at a later stage, be set aside for being erroneous-Writ is not maintainable [S. 92C, 92CA, 144C(5), 253, Art. 14, 19(1)(g), 226, 265]

S. 143(2) : Assessment-Notice-Assessing Officer can issue more than one notices-Writ is not maintainable to quash third notice. [Art. 226]

S. 132 : Search and seizure-Warrant of Authorisation-Search proceedings against company-Application of mind-Warrant of Authorisation is held to be valid. [Art. 226]

S. 115JB : Book profit-Amount disallowed u/s. 14A cannot be included. [S. 14A]

S. 92C : Transfer pricing-Arm’s length price-Captive service provider-Depreciation-Transfer pricing officer to exclude depreciation from cost and Comparables. [S. 32, R 10B(1)(e)]

S. 80IB(10) : Housing projects-Owner of land outsourcing the construction work-Entitled to deduction.

S. 45 : Capital gains Buy-back of shares by Indian subsidiary from German holding company-Liable to tax-Final liability would be lesser of that under normal provisions and under section 115JB-Subsidiary liable to deduct tax at source on payment on buy-back. [S. 46A, 47(iv), 47A, 49,115JB, 195]

S. 45 : Capital gains-Transaction of sale of shares not liable to tax-Motive of tax avoidance not relevant so long as act within the frame work of law-Transaction not with intent to avid tax-DTAA-India-Mauritius. [S. 245R(2), Art. 13(4)]