S. 143(3): Assessment-Amalgamation-Assessment order passed in name of non-existent assessee amalgamated company after informing Department duly informed about merger-Participation in proceedings no estoppel against law-Assessment order quashed and set aside.[S. 144B, 144C, Art. 226]

S. 143(3): Assessment-Firm-Additional capital by partners-Fund flow established-Matter remanded to the Assessing Officer to consider the additional documents provided by the assessee. [S. 68, 142(1), Art. 226]

S. 143(3): Assessment-Principles of natural justice-Covid-19 pandemic-Not granting sufficient opportunity-Matter remanded to Assessing Officer to consider afresh after giving due opportunity to assessee.[S. 144B, Art. 226]

S. 143(3): Assessment-Order passed without giving assessee adequate opportunity to cross-examine parties summoned under section 133(6)-Violation of principles of natural justice-Notices and orders not valid-Matter remanded to the Assessing Officer. [S.68, 69C, 133(6), 144B, 260A]

S. 143(3): Assessment-Appeal was filed against assessment order within extended limitation period granted by Supreme Court owing to pandemic-Writ petition dismissed-The assessee was relegated to statutory remedy of appeals before the Commissioner (Appeals) under section 246A and the Tribunal under section 253.[S. 246A, 253, Art. 226]

S. 143(3): Assessment-Validity-Unable to access Department’s portal-Order quashed-Matter remanded for reconsideration subject to payment of costs of Rs.10000 by assessee to the Adyar Cancer Institute, Chennai. [S. 142(1), Art. 226]

S. 143(3): Assessment-Principle of natural justice-Allegation that assessee had not been heard not proved-Writ petition dismissed-Given liberty to file statutory appeal.[S. 142(1), 147, 148, 246A, Art. 226]

S. 139 : Return of income-Audit-Profession or business-Principle of natural justice-Order treating return as invalid without assigning reason not valid-Order set aside. [S. 139(9), Art. 226]

S.139: Return of income-Limitation-Where assessment order was passed and consequential demand raised by treating return and audit reports as belated without considering CBDT Notification dated 31-12-2020 extending time limits due to COVID-19 under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, the order was unsustainable-Return and audit reports filed on 14-02-2021 were within extended time up to 31-03-2021-Assessment order and demand set aside and Department directed to open e-portal to enable assessee to upload reports, if any. [Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, Art.226]

S.92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Market value of electricity-Indian Energy Exchange not comparable to supply by State Electricity Boards-Comparable uncontrolled price method not applicable in case of material dissimilarity-Deletion of transfer pricing adjustment justified. [S.80-IA(8), 92B, 92BA, 92C, 92F, 260A]