S. 201 : Deduction at source-Failure to deduct or pay-Short deduction-Assessee in default-Retainership fees-Matter remanded.[S. 197-201(1), 201(IA)]

S. 194C : Deduction at source-Contractors-Year end provision for expenses-Payee is not identifiable-Invoices received next year-Provision is reversed-Tax deducted at source-Assessee Could not be treated as in default for mere book entries in absence of ascertainable amount and identifiable payee. [S. 194I, 194J-201(1),201(IA)]

S. 153C : Assessment-Income of any other person-Search-Additional ground is admitted-Six years to be reckoned prior to date of receipt of seized material of other person-Seized document handed over to Assessing Officer on 18-9-2018-Six years to be reckoned from AY. 2013-14 to 2018-19-Assessment for the assessment year 2011-12-2012-13 is bad in law hence quashed. [S. 132, 254(1)]

S. 153A : Assessment-Search-No incriminating material is found-Proceedings is held to be invalid-No failure to disclose material facts-Reassessment proceedings in valid-Books of account not rejected-Addition on account of alleged increase in margin is deleted. [S.28(i), 145-148-148]

S. 147 : Reassessment-Validity-Estimate of value of assets by Valuation Officer-Transfer of Development Rights-Valuation referred to Valuation Cell-Subject matter of appeal-Limitation–Order of reassessment passed on ground time-limit would expire without waiting for Report-incorrect-Order is bad in law. [S. 142A(7)-143(3), 148, 153]

S. 147 : Reassessment-Reassessment-Treating loss and gains from Marked-To-Market instruments by different methods-Non application of mind-Reassessment is valid-Commissioner (Appeals) not discussing facts properly without discussing on facts-Matter remanded to the Assessing to consider issue De Novo in accordance with law. [S. 10AA-148]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Audit objection-Reassessment is bad in law-Delay of 230 days is condoned. [S. 143(3), 254(1)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Matter remitted with direction to consider quarterly results and work out proportionate profit margin of company.

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Turnover filter-Turnover filter up to ten times can be applied-Matter restored to the file of Assessing Officer. [S.92B]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Advertisement, marketing and promotion expenses-Burden is on revenue. [S.92CA(3)]