S. 147 : Reassessment-Audit party note is not information-No failure to disclose material facts-Reassessment is not valid-The tax effect below prescribed limit-Appeal of department is dismissed. [S. 148, 253]

S. 147 : Reassessment -Incorrect assumption of fact-Recording of reason that the assessee has not filed the return-Return was filed before recording of reasons-Reassessment is held to be invalid. [S. 148]

S. 143(3) : Assessment-Amalgamation of Companies-Additional ground-Legal issue-Non issue of notice-Assessment is held to be void ab initio. [S. 143(2), 254(1)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Turnover filter-Turnover of more than Rs.200 crores was excluded-Market support services-Operating cost Matter remanded. [S. 92]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Companies Engaged In Providing High-End Integrated Services, Having Huge Brand Name And Significant Intangibles Cannot Be Compared-Gains or loss arising from Fluctuation of Foreign Currency to be considered as operating in nature-working capital adjustment to be allowed on actual basis without any restriction.-Directions of Dispute Resolution Panel cannot be construed as setting aside of issue to Transfer Pricing Officer. [S. 92CA, 144C(8)]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method (TNMM)-Held to be appropriate method-Remanded TPO to apply TNMM method. [S. 92]

S. 68 : Cash credits-Purchases-Credit balance outstanding-Deleted the addition.

S. 56 : Income from other sources-Allotment of shares-Valuation Discounted Cash Flow Method-Assessing Officer cannot change the method of valuation-Matter remanded. [S. 56 (2)(viib)]

S. 44 : Insurance business-Income from shareholders’ accounts to be assessed as insurance business-Actuarial valuation-Norms regarding actuarial valuation not altered-Dividend exempt-Disallowance is not applicable. [S. 10(34), 14A, 37(1), 80G, Insurance Act 1938, 3(4)(f)]

S. 43B : Deductions on actual payment-Employees’ contributions to provident fund and employees’ State Insurance Contribution-Paid before due date of filing return-Entitle to deduction. [S. 139 (1)]