S. 132 : Search and seizure-Reasonable belief- All three conditions must be satisfied-Satisfaction note – Failure to disclose capital gains–Absence of jurisdictional pre-requisites for exercise of power under section 132 Search and seizure illegal Revenue granted liberty to initiate reassessment proceedings in accordance with law–Warrant of authorisation quashed and subsequent search and seizure illegal-Competent authority not empowered to issue notice under section 131 (1) after initiation of search and seizure under section 132(1) Notice issued after search and seizure unsustainable-Interpretation of taxing statutes Strict interpretation and compliance.[S 45, 55(2)(ac), 131(1), 132, 147, 148, Art. 226]

S. 127 : Power to transfer cases-Facilitate co-ordinated investigation of cases-Order of transfer was valid.[Art. 126]

S. 115JB : Company-Book profit -Expenditure towards corporate social responsibility-No basis for excluding expenditure on corporate social responsibility for determining book profits-Book profits to be determined as per accounts maintained in accordance with law Income-tax Act.

S. 92C : Transfer pricing – Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Entertainment business- Royalty Payment-Transfer Pricing Officer cannot examine commercial expediency. Royalty payable under licence agreement. No question of law arose regarding disallowance on account of royalty paid by assessee to associated enterprises. Order of Tribunal affirmed. [S. 9(1)(vi), 260A]

S. 92C : Transfer pricing – Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Arm’s length price-No substantial question of law.[S. 260A]

S. 92C : Transfer pricing – Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Principle of natural justice-Notice and grant of approval by Principal Commissioner quashed and set aside-Matter remanded to Assessing Officer for considering matter afresh after hearing assessee and thereafter to pass speaking order.[S.92CA(1), 92CA(2), 92CA(3), Art. 226]

S. 69A : Unexplained money-Post-demonetisation deposit of old currency notes-Cash book balance insufficient to explain deposit – Failure to explain the source – Addition was affirmed.[S. 260A]

S. 69A : Unexplained money – Denominations – Details not maintained – Nature of source of cash deposit was not explained satisfactorily – SLP of assessee dismissed. [Art. 136]

S. 45 : Capital gains-Accepted cost of acquisition – Difference between intrinsic value of shares and amount paid by assessee cannot be taxed as perquisites – Order of Tribunal deleting the addition is affirmed. [S. 2(24)(iv), 260A]

S. 40A(3) :Expenses or payments not deductible-Cash payments exceeding prescribed limits-Payments to agents cannot be disallowed – Order of Tribunal set aside. [ITR, 1962 R. 6DD, Indian Contract Act, 1872, S. 182.]