S. 147 : Reassessment-After the expiry of four years-Derivative losses-Report of Investigation Directorate-Commodities transaction-Reassessment notice was held to be not justified. [S. 4, 143(3), 148, 153A]

S. 144C : Reference to dispute resolution panel-Issue of notice of demand along with draft assessment order-Assessment order is not bad in law. [S. 92C]

S. 143(3) : Assessment-Difference in amount of income shown between ITS/26AS viz-a-viz income accounted in books of account-Failure to reconcile the difference-Addition is held to be justified.

S. 143(3) : Assessment-Civil construction business-Difference in 26AS and actual receipts-Matter remanded back to the Assessing Officer.

S. 115JB : Book profit-Provision for diminution in value of investment-Written off in books of account-Addition cannot be made. [S. 115JB(2)(i)]

S. 115BBE : Tax on specified income-set-off of any loss-Entitled to claim set-off of loss against income determined under till assessment year 2016-17. [S. 68 to 69D]

S. 92C : Transfer pricing-Arm’s length price-Advertisement expenses-No agreement between AE-Adjustment was deleted-adjustment of royalty was deleted.

S. 92C : Transfer pricing-Arm’s length price-Factors to be considered while accepting comparables-Web enabled customer care services, BPO services-Health care BPO services-Revenue filter-Held to be not comparable-Turnover of comparable company was 509 times-Not comparable-High Brand value-Not comparable.

S. 92C : Transfer pricing-Arm’s length price-Functional similarity-Business of manufacturing and distributing products of consumer electronics and home appliances category-Providing an online marketing platform for sale of electronic products of multiple brands-Designing and manufacturing of only mobile phones-Having brand owning and outsourcing its manufacturing activities to third party contractors could not be accepted as a valid comparable-Would not be accepted as a valid comparable.

S. 92C : Transfer pricing-Arm’s length price-Export of customers electronic data-Comparable-Functionally different-Not acceptable as comparable-Interest receivable-No separate adjustment for interest on receivable was to be made.