S.147: Reassessment — Accommodation entry -Information from Director of Income-Tax- No application of mind or independent inquiry or link between any tangible material- Reassessment not valid.[ S.148 ]

S. 147 : Reassessment –With in four years- Change of opinion- Sale of agricultural land available on record at time of original assessment — Book profit – Agricultural Land — Gains on sale of agricultural land not deductible- Reassessment is held to be not valid [ S. 2(14((iii) , 115JB ,148 ]

S.147:Reassessment — Accommodation entries- Share application and share premium- No failure to disclose any material facts – Assessing Officer not mentioning names of parties from whom receipt of accommodation entry in reasons — Reassessment held to be not valid.[ S.68 , 148 ]

S.143(3):Assessment — Conversion of limited scrutiny into complete scrutiny — Assessing Officer is bound to follow the instructions -Prior approval from competent authority mandatory —In the absence of communication in writing to Assessing Officer about approval, assumption of jurisdiction by Assessing Officer invalid .[ S.54B ]

S.115JB: Book Profits — Subsidy received in form of Excise Duty refund for establishment of new industrial undertaking — Capital subsidy not liable to tax — Excludible from computation of book profits.

S. 115JB : Book profit – Retention money – Not to be considered for computing book profits – Exemption under section 80IA is not allowable while computing book profit- Secondary and higher education cess- Deduction can be claimed in appellate proceedings [ S. 40(a)(i), 80IA 254(1) ]

S.115BBE: Tax on income- Unexplained money —Part of unrecorded sales Addition Cannot be made- Surrendered income – Business income -Eligible deduction under section 80JJA . [ S.69A, 80JJA ]

S. 92CA :Reference to transfer pricing officer -Arm’s length price —Computing Arm’s Length Price without referring matter to Transfer Pricing Officer — Transfer adjustment vitiated – Draft assessment order does not become final assessment order simply by issuing corrigendum — Draft assessment order not valid. [ S.92CA(3) 144C ]

S. 92C : Transfer pricing – Arm’s length price – Comparable Benchmarking of Transaction — Marketing support services same functions – Can be treated as comparable —Deriving its income from manufacturing or trading and indenting services — Not good Comparable for company rendering market support services.

S. 92C : Transfer pricing – Arm’s length price – Debt-free company —Adjustment in relation to notional interest on overdue receivables is held to be not justified- Comparable – Company having controlled transactions — High brand value and high turnover of company —Held not comparables.