S. 127 : Power to transfer cases – Transfer from one Commissioner to another – Search and Seizure – Connected – Notice must be specific – Failure to deal with reply of assessee – Notice was quashed . [ S. 127 (1). 127(2) , 132, Art , 226 ]

S.37(1): Business expenditure – Salary , professional fees etc – Allowable as revenue expenditure

S. 36(1)(vii) :Bad debt – Advances made in the course of business – Interest income was assessed as business income in earlier year- Advances written off – Allowable as bad debt . [. S.36(2)(i), 37 (1) ]

S. 9(1)(i): Income deemed to accrue or arise in India – Representative assessee — Trustee – Business connection -British Virgin Islands by company registered in Jersey- Trust in Jercy becoming sole beneficiary – Power to make investment in in India – Foreign Trustees recognised by Indian Income-Tax Law — Arrangement for purposes of commercial expediency – Income that accrued to the trust would not be chargeable to tax in India either by virtue of application of section 61 read with section 63 or section 161 of the Act conjointly with the provisions of article 24 of the DTAA. Income accruing – Ruling of AAR was quashed – DTAA-India -UAE [ S. 5(2), 10(23FB) 61, 62, 63 , 90, 160 , 161, 245-0, Indian Trusts Act, 1882, S. 1,3 , Art , 4 (2)(d), 24 ]

S. 147 : Reassessment – After the expiry of four years – Subsequent search and Seizure of another party – Loan activity not established – Recorded reasons must indicate the manner in which the Assessing Officer has come to the conclusion that income chargeable to tax has escaped assessment – Reason recorded cannot be substituted – Reassessment Notice was quashed .[S. 68 , 132, 133A, 148 , 153A, Art , 226 ]

Direct Tax Vivad Se Vishwas Act , 2020 .

S. 2(1)(a)(i): Person – Pendency of appeal – Application for condonation of delay was pending before CIT(A)- Notice of hearing was issued – Rejection of application on the ground that the appeal was not admitted was held to be not justified -Order of rejection set aside [S. 2(1)(a) (n), ITAct, S. 246A, 250 Art , 226 ]

S. 147: Reassessment – After the expiry of four years – Builder stock in trade- Notional income – Reassessment notice on the basis of Judgement of Delhi High Court in Ansal Housing Finance and Leasing Company Ltd ( 2013 ) 354 ITR 180 (Delhi)(HC) to assessee the income under section 23 of the Act was quashed [ S. 22, 23(5) , 148 , Art , 226 ]

S. 151 : Reassessment – Sanction for issue of notice – Issuance of Notice requires the sanction of PCIT where the Notice is issued after 4 years – Relaxation Act not a bar for appropriate sanction- Reassessment notice is held to be bad in law . [ S. 147, 148 , Art , 226 ]