S.147: Reassessment —Wrong facts and figures- Non-application of mind —Reassessment is held to be not valid [ S. 68, 148 ]

S.147: Reassessment-After the expiry of four years- Cash credits – All material facts were disclosed in the original assessment proceedings -Reassessment is held to be not valid [ S.68 , 148, 194A ]

S. 145 : Method of accounting – Fall in net profit rate -No specific defects pointed out in the books of account – Remand report – Addition of higher rate of profit is held to be not justified .

S. 92CA :Reference to transfer pricing officer – Transfer pricing – Specified domestic transaction — Unreported transaction — No power to determine arm’s length price without approval from principal commissioner or making reference to him [ S.92C ]

S. 92C : Transfer pricing – Arm’s length price – Comparable- Software testing services company — Company rendering whole basket services — Company providing software services to its clients — Not Comparables.

S. 92C : Transfer pricing – Arm’s length price – Foreign exchange gain or loss- Comparable- Comparability position on year to year basis independently to be examined – Provision for doubtful debts . [ S.92CA ]

S. 92C : Transfer pricing – Arm’s length price -Shipping business- Tonnage taxation scheme – Interest on purchase of two ships- No application of transfer pricing provisions to income covered under tonnage tax scheme – Guarantee commission- Assessing Officer is directed to make adjustment by applying 0.25 Per Cent. To Transaction Instead of 0.5 Per Cent- Advance to share application money – Shares not allotted -Full money refunded- loan – Rate of interest to be applied on amount at Libor- Service agreement – Interest to be confined up to end of year and not thereafter.

S. 80IB(10) : Housing projects- Completion certificate is not obtained for certain flats —Not entitled to deduction in respect of those flats — Development plan road acquired by Municipal Corporation not be reduced from total land area of project.

S. 69C : Unexplained expenditure -Bogus purchases – Sales not doubted – Quantitative tally of purchases of meat and exports furnished – Addition is held to be not justified .

S. 68 : Cash credits – Share premium — Identity and creditworthiness of share holders and genuineness transaction is not doubted – Merely for not furnishing the valuation report -Addition is held to be not justified .