S. 153 : Assessment–Reassessment–Limitation–Direction by CIT(A) to assess income in the hands of another person can be given only if an opportunity of being heard is given to such other person- Matter remanded to CIT(A). [S. 147, 148, 149, 150]

S. 147 : Reassessment–Notice–Expenditure on contact charges -Allegation of charges were high-Reopening on issues examined in detail in the assessment is bad in law. [S. 37(1), 69C, 148]

S. 147 : Reassessment–Notice–Not to be quashed if appeal on similar issue pending in another Assessment year. [A. 226, S. 115BBC]

S. 147 : Reassessment – Survey -Non disclosure of Royalty and FTS in the original return-Reassessment is held to be justified. [S. 133A, 148]

S. 147 : Reassessment–Notice-License fee-Use of logo -Capital or revenue – Reopening solely based on audit objections not permitted as it amounts to change of opinion. [S. 37(1), 147]

S. 147 : Reassessment–Based on subsequent finding of DRP that there was no Permanent Establishment of the assessee in India– AO dropped reassessment proceedings–Order passed by High Court upholding validity of those proceedings was to be set aside. [S. 148]

S. 132A : Powers-Requisition of books of account–Reasons to believe to issue requisition notice not required to be disclosed to any person or Authority or Appellate Tribunal. [S. 254(1)]

S. 92C : Transfer pricing-Arms’ length price–Selection of comparables-Remand to the AO-Held to be proper. [S. 254(1)]

S. 92C : Transfer pricing-Arms’ length price–Tribunal’s remand for ALP determination on a combined basis not an academic exercise- Order of Tribunal is affirmed. [S. 254(1)]

S. 92C : Transfer pricing-Interest chargeable on delayed recovery of export receivables and expenses–LIBOR rates should be taken instead of SBI PLR. [S. 144C]