S. 147 : Reassessment-After the expiry of four years-Full and true disclosure-Change of opinion-Books seized not returned-Unable to draw balance-sheet-Subsequently drawing the balance sheet-Assessment under section 143(3) of the Act-Return not treated as defective-Subsequent subjective analysis of Assessing Officer that income of assessee was much higher than that assessed- Change of opinion- Reassessments are not justified-Once primary facts disclosed by assessee, burden shifts to Assessing Officer-Defective return-Burden on Assessing Officer to intimate defect to Assessee for rectification within time specified- Assessing Officer not exercising discretion- Return cannot be construed as defective burden on Assessing Officer to intimate defect to Assessee for rectification within time specified. [S. 139(9)(f), 145(1) 147, 149(1)(b)(iii)]

S. 147 : Reassessment-After the expiry of four years-Different method of accounting-Capital gains-Computation-No failure to disclose material facts-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 45, 48, 112(1)(c)(ii), 143(3) 148, Art, 136]

S. 144C : Reference to dispute resolution panel-Order passed under remand proceedings also has to follow mandatory procedure-Final assessment order without following the procedure is bad in law and unlawful.[S. 144BA(12), 144C(14A),263 Art.226]

S. 143(3): Assessment-CBDT Circular No. 14 Of 1955- Duty of Assessing Officer to grant relief to assessee even if not claimed-DTAA-India-USA.[S.119, 139,143(1), 260A, art.12]

S. 143(2): Assessment-Notice-Assessment quashed on the ground that instructions issued by CBDT for selection of cases for scrutiny were not satisfied in the instant case-High Court confirmed the Tribunal order.[S.119, 144]

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Tribunal holding Transfer Pricing Officer not empowered to hold transaction sham- High Court affirmed. [S. 37(1), 92C, 260A]

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Tribunal holding Transfer Pricing Officer not empowered to hold transaction sham- High Court affirmed-Special Leave Petition Dismissed- Question of law kept open. [S. 37(1), 92C, Art.236]

S. 80JJA : Bio-degradable waste-Collecting and processing-Undisclosed closing stock of a trading concern-Income not derived from the activity of manufacturing-Addition of entire stock as income justified-Business expenditure-Expenditure not supported by vouchers-Restriction of disallowance to 10 percent of expenditure is held to be justified. [S. 37(1), 260A]

S. 69C : Unexplained expenditure-Bogus purchases-Sundry creditors-Only profit element embedded in credits can be taxed-Restricted to 25% of element of profit-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 37, 69A, 143(3), Art.136]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Freight charges-Payments to contractor- Excess of Rs. 50,000 without deducting tax at source-No evidence to prove that there was no contract- High Court held that disallowance is justified- Special leave granted.[S. 194C, Art. 136]