S. 147 : Reassessment-After the expiry of four years-Cash credits – Share capital- Mauritius based company-Supplied certificate of foreign inward remittance of funds, tax residence certificate of foreign company, copy of ledger account showing share application money being credited in bank account and source – Merely on the basis of information from investigation Wing,reassessment is bad in law. [S. 68]

S. 147 : Reassessment-After the expiry of four years-Possession of cash amount- All documents were made available at time of original assessment- Reassessment merely on basis of change of opinion was held to be not justified. The fact that the assessee did not disclose the material is not relevant if the AO was otherwise aware of it[S. 69A, 133A, 148],153A

S. 147 : Reassessment-After the expiry of four years-Interest paid on purchase of securities-expenditure for increase in capital–loss on securities-Excess claim of depreciation-There was no failure on part of assessee to disclose fully and truly all relevant material- Reassessment is bad in law.[S. 32, 36(1), 148]

S. 92C : Transfer pricing–Arm’s length price-Only one comparable-Difference in functionality- Matter remanded.

S. 92C : Transfer pricing–Arm’s length price–Export of finished valves and valves in kit form to its AE and also to its group companies across globe -TPO ought to have arrived at ALP of assessee’s sale to its AE by only comparing it with uncontrolled transaction of sale. [S. 92]

S. 80IB : Industrial undertakings-Profit from sale of slag, which was a by-product in manufacture of pig iron, was to be considered as profit from business of industrial undertaking engaged in manufacture and sale of pig iron for purpose of deduction.

S. 72 : Carry forward and set off of business losses–Return was not filed with in prescribed time–Application for condonation of delay was not filed with in permissible time limit – Rejection of application is held to be justified. [S. 119, 139(1), 254(1)]

S. 69C : Unexplained expenditure–Hawala transaction-Bogus purchases–Trading in paper and paper products-Adoption of profit at 12.5 % of alleged bogus purchases is held to be justified. [S. 143(3)]

S. 54B : Capital gains – Land used for agricultural purposes– Denial of exemption on the basis of report of inspector and statement of bataidar is held to be justified. [S. 45]

S. 45 : Capital gains-Transfer- Agreement to sell flats which were yet to be constructed–No transfer has taken place during the year -Not assessable as capital gains. [S.2(47)(v), Transfer of property Act, 1881, S. 53A]