S. 147 : Reassessment-After the expiry of four years-Research and development expenditure-Change of opinion-Reassessment notice in respect of first ground was up held and in respect of second ground is held to be not valid. [S.133A, 148, Art. 226]

S. 145 : Method of accounting-Valuation of shares-No substantial question of law. [S. 260A]

S. 145 : Method of accounting-Set aside order by Appellate Tribunal-Fresh order passed by the Assessing Officer-Order of Tribunal is affirmed. [S.254 (1)]

S. 143(3) : Assessment-Suppression of sales-Addition is held to be not justified on the basis of material collected from Excise Department. [S. 68, 145]

S. 143(3) : Assessment-In adequate sale consideration based on valuation report-Deletion of addition is held to be justified.

S. 143(2) : Assessment-Notice-non-issuance of notice under section 143(2) is not a procedural irregularity and same cannot be cured under section 292BB-Notice issued to prior to filing of return of income, said notice being invalid, assessment order passed in pursuance of same deserved to be set aside. [S. 143 (3), 292BB]

S. 132 : Search and seizure-Stock in trade-Gold Dore Bars-Directed to be released after proper verification. [Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Adjustment-MAP-ITAT is justified in in directing to adopt 16.63% Arm’s Length margin for transaction relating to non US entities based on MAP concluded with US Tax Authorities.

S. 92C : Transfer pricing-Arm’s length price-Comparable-company having high brand value cannot be selected as comparable.

S. 92C : Transfer pricing-Arm’s length price-Safe Harbour rules-RBI rate to be a bench mark-Second proviso to section 92C(2) which allows +/-5 per cent range to could be applied even in a case where transactions involved were an account of trading in foreign exchange.