S. 143 (3): Assessment-Cash credits-Principle of natural justice-Personal hearing is not granted though video conference-In view of Circular dated 6-9-2019 where personal hearing was not technically possible through video conference, then personal hearing ought to be conducted in a designated area in Income-tax office-Matter remanded back to Assessing Officer to give opportunity of hearing to assessee.[S. 68, 263, Art. 226]

S. 143 (3): Assessment-Merger-Assessment order in the name of transferor company is quashed and set aside. [S. 148, Art. 226]

S. 132(3) : Search and seizure-Prohibitory order-Article-Liquor-Contention of Revenue that liquor cannot be included in the expression of valuable article is rejected-Order issued under section 132(3) is quashed on the ground that Revenue could have invoked section 132(1) of the Act-SLP of Revenue is dismissed. [S. 132, Art. 136]

S. 127 : Power to transfer cases-Search-From ITO Delhi to DCIT, Karnal Haryana-Incriminating material-Transfer of case on grounds of administrative convenience and meaningful assessment-Writ petition is dismissed. [S. 124,131(IA), 132, Art, 136]

S. 127 : Power to transfer cases-Opportunity of hearing-No reasonable opportunity had been provided before transferring case and officer of Bangalore to Delhi-Order of single Judge is affirmed.[S. 124, Art. 226]

S. 127 : Power to transfer cases-Opportunity of hearing-Bangalore to Delhi-High Court held that no opportunity of hearing was given-Order High Court is affirmed-SLP of Revenue is dismissed.[S. 124, Art. 136]

S. 127 : Power to transfer cases-Search-From ITO Delhi to DCIT,Karnal Haryana-Incriminating material-Transfer of case on grounds of administrative convenience and meaningful assessment-SLP is dismissed.[S. 124, 131(IA), 132, Art, 136]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Online market support services-Allocation of expenses-Expenditure for un-allocable costs could be allocated on basis of proportionate turnover of concerned segment-Open to accept one or other principle i.e turnover method or headcount method-Choice of assessee in relying upon headcount principle per se could not be rejected-SLP of Revenue is dismissed due to low tax effect.[Art. 136]

S. 90 :Double taxation relief-Foreign tax credit-Australian branch-Reasons for such denial could not be discerned and such facts and circumstances warranted reconsideration, matter was to be remanded for reconsideration in so far as tax credit claim was concerned-DTAA-India-Australia.[Art. 24, Art. 226]

S. 90 : Double taxation relief-DTAA overrides provisions of section 206AA-Rate of tax to be applied for grossing up should be as per DTAA-No substantial question of law. [S. 206AA, 260A]