S.147: Reassessment-After the expiry of four years- Share premium- No failure to disclose material facts- Reassessment notice on mere surmise that the assessee had received amounts as share premium is held to be not valid .[ S.148 ]

S.143(3): Assessment – Estimation of rate of gross profit- Direction of the Tribunal – AO has followed the direction of Appellate Tribunal – Addition made by the AO is held to be valid . [ S.132 , 158BC, 254(1) ]

S. 92C : Transfer pricing – Arm’s length price – Comparable uncontrolled price method- The arm’s length price determined was not in excess of the invoice price by more than 5 per cent. The price fixed by the Transfer Pricing Officer was justified . [ S. 92A, 92B ]

S. 92C : Transfer pricing – Arm’s length price -Selection of comparables —Exclusion of dissimilarities of function is held to be justified- Appellate Tribunal- Additional evidence -Tribunal directed to examine issue of asessee’s involvement in activity of software development considering additional evidence produced .[ S.254(1)

S. 80P : Co-operative societies – Entitle to deduction – Reassessment notice is held to be not valid . [ S.2(19) , 147, 148, Constitution of India , Art , 226 , Karnataka Co-Operative Societies Act, 1959, S. 2(D-2) ]

S. 80IA :Industrial undertakings – Generation of Power- Captive Consumption — Valuation of profits to be taken at rate distribution companies allowed to supply electricity to consumers.

S. 80IA :Industrial undertakings – Business income -Income from other sources – Interest on deposit of margin money and interest on belated payments by customers is assessable as business profits – Entitle to deduction . [ S.28(i) , 56 ]

S. 80HHC : Export business – Supporting manufacturer – Certificate by main exporter and report of Chartered Accountant is mandatory- Failure to comply the same deduction is not available. [ S.80HHC(IA) ]

S. 80G : Donation – Charitable Trust – Charitable Trust should be registered under Section 12A for availing the benefit .[ S.(2(15), 11, 12A, 12AA ]

S. 69 :Unexplained investments -Income from undisclosed sources — Addition is held to be not justified merely on the basis of statement made by partner before Custom authorities . [ Customs Act, 1962, S. 108 ]