S. 145 : Method of accounting-Rejection of books of account-Estimation of profit-Rejection of books of account is justified-Estimate of @ 5 percent of the turnover is affirmed-Jurisdiction issue is not challenged in the course of assessment proceedings hence not entertained-Reassessment is affirmed. [S. 124(3),145(3), 147, 148]

S. 144C : Reference to dispute resolution panel-DRP cannot set aside any proposed variation or issue any direction for further enquiry-Direction issued to the Assessing Officer to pass a speaking order in respect of Permanent Entablement is contrary to the provisions of section 144C(8) [S. 9(1)(i), 144C(8)]

S. 143(3): Assessment-Jurisdiction-Assessment order passed by non-Jurisdictional Assessing Officer-Contrary to CBDT instruction No. 1 of 2011 dt. 1-4-2011-Order is bad in law. [S. 119,124(3), 143(2)]

S. 143(2) : Assessment-Notice under section 143(2) was issued by non-jurisdictional Assessing Officer-Matter remanded to the Assessing Officer to verify as to territorial jurisdiction at the time of issue of notice. [S. 143(2)]

S. 143(1) : Assessment-Intimation-Invalid return-CPC has no jurisdiction to process the return and disallow the claim. [S. 139(9)]

S. 139 : Return of income-Capital loss-Short term capital loss-Carry forward-Entitle to the benefit of extended due date of filing upto 31st October 2019 [S. 74, 80IA(7), 139(1), Expl. 2(a)(ii)]

S. 112 : Tax on long term capital gains-Determination of tax in certain cases-Non-resident-Sale of unlisted shares-Capital gains had to be computed only by reference to provisions of section 112(1)(c)(iii), without giving effect to first and second provisos to section 48. [S. 45, 48, 112(1)(c)(iii)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Sale of low volume of exports cannot be considered as valid comparable-Adjustment made adopting the ALP of interest at six moths average of LIBOR plus 3. 5 % % is not sustainable.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-TPO accepted cost allocation on basis of average total assets and third party sales, but refused to accept allocation done on basis of head count-Addition on account of management fee is deleted. [S. 92CA]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Property is purchased by an Indian enterprise from its AE and is resold as such without any value addition, it is RPM, being specific method, which would hold field in preference to TNMM-Percentage of related party transactions of expenses of selected company was more than 57 per cent of total expenses incurred by it, selected company could not be held as comparable-Comparable-Assembly activity-Engaged in multi-dimensional ranging business and also into field of constructing-production of electronic weighing scales, currency counting machine-business of manufacturing, marketing and servicing of road and rail weigh bridges-Not comparable. [S. 92CA]