S.14A : Disallowance of expenditure – Exempt income – AO has neither considered contention of the assessee nor recorded the satisfaction, hence disallowance is not justified.[ R.8D ]

S. 12AA : Procedure for registration –Trust or institution- Amount received from settler company and same was given as donation to another charitable institution , refusal of registration is held to be justified ,as the assessee has not carried out any charitable activities [ S. 2(15) ]

S. 271D : Penalty -Takes or accepts any loan or deposit –Journal entries – Penalty cannot be levied if the transactions are bona fide ,genuine and reasonable cause.No substantial question of law [ S. 260A,269SS, 269T, 273B ]

S.147: Reassessment – After the expiry of four years- Carry forward the loss- No failure to disclose all material facts -Reassessment is bad in law [ S.79, 148 ]

S. 143(3): Assessment – Estimate of cost of construction- Books of account not rejected – Assessing Officer cannot refer the matter to District valuation Officer .

S.260A: Appeal -High Court -Departmental Counsel- CBDT should re consider the practice of appointing retired revenue officers as panel counsel. CBDT should lay down a standard procedure in respect of manner in which the Departmental Officer/ Assessing Officer assist the Counsel for the Revenue while promoting/ protecting Revenue’s cause so that the Revenue’s Counsel are not left to fend for themselves. Copy of the judgement was forwarded to Chairman CBDT.

S. 253: Appellate Tribunal -Registrar’s Court -The Registrar of the Tribunal has no jurisdiction to consider and decide on applications for condonation of delay. Only the Court/ Tribunal have the power. The order passed by the Registrar is ultra vires his power and non est in law. He should desist from passing such orders [ S. 152(1).253(5) ]

S. 158BB: Block Assessment-Survey- Material found in the course of search and survey which has been made simultaneously made at the premises of connected person can be utilised while making block assessment [ S. 132, 133A, 158BC ]

S. 92CB: Transfer Pricing- Safe Harbour Rules- AO has no authority to make any reference to the TPO to ascertain the arm’s length price of the assessee’s specified domestic transactions. CBDT’s circular dated 10.3.2006 could not have and does not lay down anything to the contrary.[ S. 92C,92CA ]

S.92C: Transfer pricing- The “international transaction” as defined in S. 92F(v) has to be a genuine transaction. Transfer pricing provisions do not apply to non-genuine or sham transactions [ S.92F( v) ]