S. 147 : Reassessment–With in four years-Change of opinion Interest income-Income from other sources–Adjustment of interest income against interest expenditure and remaining amount was transferred to work-in-progress account-Reassessment is held to be not valid. [S. 56, 148]

S. 145 : Method of accounting–Stock valuation-Cash credit limits-Discrepancy in stock as per books of account of assessee and that shown in bank statements–Deletion of addition is held to be justified.

S. 145 : Method of accounting–Stock valuation of gold-LIFO method of valuation–Recognised in law–No substantial question of law. [S. 260A]

S. 145 : Method of accounting–Trading in rice-Assessing Officer was justified in accepting two entries relating to profits and disregarding other two entries concerning losses.

S. 144 : Best judgment assessment–Statutory remedy of appeal is available-Writ is held to be not maintainable. [S. 246, Art. 226]

S. 143(2) : Assessment–Notice–Issue of notice beyond period prescribed in proviso to S.143(2)–Assessment is barred by limitation.

S. 143(2) : Assessment–Notice-Non service of notice with in limitation period–Order is bad in law-Provision of S.292BB cannot be invoked since assessee neither appeared nor co-operated in inquiry during assessment proceedings as the order was passed u/s. 144 of the Act. [S. 144 , 292BB, Art. 226]

S. 115JA : Book profit-Provision for bad and doubtful debts is a provision for unascertained liability, and thus, same could not be excluded while computing book profits-Provision made for payment of purchase tax, payment of purchase tax on cane subsidy and provision for wealth tax, in anticipation of Government Notification, were provisions for unascertained liability, liable to be added back while computing book profits. [S. 36(1)(vii)]

S. 92CA : Reference to transfer pricing officer – AO is not bound to pass draft assessment order in tune with arm’s length price fixed by TPO-AO having rejected valuation of shares made by TPO, made addition to assessee’s income in respect of excess price paid for buy-back of shares-Writ was dismissed-liberty is given to the to the assessee raise all the issues before the Dispute Resolution Panel. [S. 2(22) (iv), 46A,56(1), 92CA 94, 115QA, 144C, Companies Act, 1956, S.72A, R.11UA, Art. 226]

S. 92C : Transfer pricing-Arms’ length price-Services of application design, software engineering and technology cannot be compared with a company providing software support services.