S. 147 : Reassessment-Search and seizure-Seized ground not related to the assessee-Reassessment is bad in law. [S. 132]

S. 147 : Reassessment-After the expiry of four years-Transfer pricing-Arm’s length price-Tribunal order in earlier year assessment years-No failure to disclose material facts-Reassessment is not valid. [S. 148]

S. 143(3) : Assessment-Jurisdiction-Filing returns at Meerut-Notice for scrutiny assessment issued by Officer at Malegaon-No material to show how or why case transferred-Notice by Officer not having jurisdiction-Assessment invalid. [S. 127, 143(2)]

S. 143(3) : Assessment-Unexplained money-Cash found during search-Sale of scrap-Reflected in balance sheet-Addition cannot be made. [S. 69, 69C, 132]

S. 143(3) : Assessment-Protective assessment-Director-Substantive addition in hands of company deleted-Protective assessment in hands of director not sustainable. [S.179, 292C]

S. 92C : Transfer pricing-Arm’s length price-Arm’s Length Price-Most Appropriate Method-Assembling goods partly purchased from its associated enterprise and partly developed by its own vendor-Resale Price Method adopted is not appropriate-Transactional Net Margin Method, Appropriate. [S. 144C]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Transfer pricing adjustment to be restricted to International Transactions rather than entity level transactions. [S. 92(1)]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method Or Cost-Plus Method-Directed to follow Cost Plus Method. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Transactional Net Margin Method-Comparables-Exclusion of companies on ground of revenue filter, non-availability of segmental data, functional dissimilarities-Held to be proper-Working capital adjustment on actual basis-allowable-Disallowance of interest would increase profits and gains derived from eligible-The addition relating to transfer pricing adjustment was not eligible for deduction under section 10A of the Act, in view of the bar provided in the proviso to section 92C(4) of the Act. [S. 10A, 92C(4)]

S. 90 : Double taxation relief-Foreign tax credit-Tax paid in USA, Japan and Germany-Credit available on all taxes paid in these countries-Tax paid in Korea-Limited to taxes payable on doubly taxes in India-Tax paid in Taiwan-No double taxation avoidance agreement with Taiwan-Foreign tax credit computed based on rate of tax applicable in India or Taiwan, whichever is less, on doubly taxable income-DTAA-India-USA-Japan-Germany-Korea. [S. 91, Art. 25, 23(2), 23(2), 23]