S. 143(3) : Assessment–Ad hoc addition-No understatement by assessee-Addition on ad hoc basis at 50% is held to be not sustainable.

S. 133A : Power of survey-unaccounted receivables–Surrender of income Deemed income-Categorization/characterization of income surrendered-business income-Set off of losses was to be allowed [S. 69A 69B]

S. 133A : Power of survey-Undisclosed income-Loose papers-Bona fide mistake by director in surrendering income-Set off of expenditure is allowable. [S. 115BBE]

S. 127 : Power to transfer cases-Opportunity of hearing–Assessee’s case was transferred from one AO to another AO having offices in different localities/places, notice had to be given to assessee-Order is held to be void ab initio and barred by limitation. [S. 127(1), 143(2), 292B]

S. 115O : Domestic companies-Tax on distributed profits–Charging section –No need for issuance of notice before making a demand–Profits distributed to share holders is deemed to be dividend-Reduction on share capital can be effected by buying back shares–Advance Ruling cannot be given if an enquiry is pending against the assessee-Writ will not normally be issued if there is alternative remedy-Liberty is given to file an appeal. [S. 2(22), 245R, 246A, Art. 226 Companies Act,1956 S. 391, 393]

S. 115J : Book profit–Only the adjustments to the extent provided in the Explanation to S. 115 can be made. [Companies Act, 1956]

S. 92C : Transfer pricing-Arms’ length price-International transactions- Benchmarking of transactions-Comparable-Back office support services-Company providing consultancy business solution and testing and high end business process outsourcing services-Cannot be held to be comparables.

S. 92C : Transfer pricing–Arm’s length exemption-Tax exemption-Arm’s length price on international transactions deserve to be determined. [S. 10A, 10B, 92]

S. 92B : Transfer pricing–Arm’s length price-Corporate guarantee given to associated enterprises–Arm’s length commission on such guarantee restricted to 0. 5%. [S. 92C]

S. 80IC : Special category States-Tea plantation–Manufacturing of tea is not eligible to claim deduction in respect of sale of black tea manufactured from green tea leaf purchased from outside market. [S. 80IC(2)(b)]