S. 147 : Reassessment – Charitable Trust- Corpus donation – Change of opinion- No new facts – Reassessment is held to be bad in law [ S. 2(15) 11, 12A , 148 Art , 226 ]

S. 144 : Best judgment assessment – Addition made cash deposited during demonetization period. – Addition on account of business income – Violation of principle of natural justice –
Matter remanded to Assessing Officer [ S.142 (1), Art , 226 ]

S. 92C : Transfer pricing – Arm’s length price – Comparable – Test of functional similarity applied by Tribunal is in consonance with legal position discussed herein above— Order of Tribunal is affirmed [ S.92B(2), 260A ]

S. 80G : Donation -Renewal of exemption is held to be justified [ S. 11, 12A, 80G (5)(iii) ]

S. 50B : Capital gains – Slump sale – Complete code – Deletion of addition is held to be valid [ S. 2(19AA), 2(42C), 48, 49 ]

S. 47(v) : Capital gains – Transaction not regarded as transfer – Subsidiary to holding company – Not necessarily whole of the shares of the subsidiary company is held by holding company – A construction which results in rendering a provision redundant must be avoided – Entitle to exemption . [ S.47 (iv)]

S. 37(1) : Business expenditure – Discount to custoners – Higher percentage than discount granted earlier year – Disallowance is arbitrary – Income- tax Authorities must put themselves in the shoes of the assessee and see how a prudent businessman would act -Books of account not rejected – Allowable as business expenditure .

S. 37(1) : Business expenditure – Deferred revenue expenditure – Advertisement publicity and sales promotion – Allowable in the year it was incurred .

S. 37(1) : Business expenditure – Provision for warranty – Held to be allowable as deduction .

S. 28(i) : Business income – Income derived from letting out of property to the tenants as income from business in the hands of the owner of the property- Assessable as business income [ S.14A, 22, 56 ]