S. 271(1)(c) : Penalty – Concealment -International transaction — Transfer pricing —Explanation of Arm’s length price is found to be bona fide—Penalty cannot be imposed- Explanation 7. [S. 92C]

S. 254(1) : Appellate Tribunal – Duties- Reasoned speaking order which is the mandate as laid down by the Supreme Court in Kranti Associates Pvt Ltd v. Masood Ahmed Khan ( 2010) 9SCC 496 and Canara Bank v. V.K Awasthy (2005) SC 2090-Non speaking orders by Tribunal as well as Commissioner (E)- Natural justice is violated matter remitted to Commissioner (E) for fresh consideration.[S. 12AA]

S. 246A : Appeal – Commissioner (Appeals) – Appealable orders –Income from other sources – Cash credits -Assessee filing writ petition—Writ Court interpreting statutory provisions in favour of revenue—Assessee cannot file statutory appeal thereafter. [Art. 226]

S. 234B : Interest – Advance tax – Salary income -An assessee whose income -tax liable to be deducted at source is not liable to pay advance tax and consequently not liable to pay interest u/s 234B(1). [S. 15, 192]

S. 147 : Reassessment—Alternative remedy- Share premium-Notice based on information — Reasons for notice furnished to assessee—Writ petition against the notice is not maintainable [ S. 68,148, Art .226 ]

S. 147 : Reassessment -Reason to believe -Based on decision of Tribunal accepting contention of Assessee’s son in his case that income was chargeable in assessee’s hands as first holder of investments in mutual funds—Formation of belief is within subjective satisfaction of Assessing officer- Notice for reopening of assessment is valid. [S. 148]

S. 147 : Reassessment—Shell companies–Bogus long term capital gains-Assessment under S.143(1)-Notice of reassessment based on information from departmental channels-Assessing Officer had no occasion to form opinion- pinion—Reassessment is held to be valid. [S. 10 (38), 45, 143(1), 148]

S. 147 : Reassessment—Doctrine of merger—Annulment of reassessment proceedings was held as invalid -The original assessment order would automatically get restored-Doctrine of merger does not apply. [S. 143(3), 148]

S. 147 : Reassessment –Issuance of notice under S. 143(2) is mandatory -Failure to issue is not procedural irregularity –S. 292BB does not dispense with the issuance of any notice that is mandated to be issued under the Act, but merely cures the defect of service of such notice if an objection in such regard is not taken before the completion of the assessment or reassessment-Entire proceedings including any order is liable to be quashed though the assessee had participated in the course of the reassessment. [S.143(2), 148, 153(2), 292BB]

S. 92C : Transfer pricing-Arm’s length price-Transactional net margin method—Exclusion of functionally different comparable companies-Finding of fact-No substantial question of law. [S. 260A]