S. 144 : Best judgment assessment-Reassessment-Schedule Tribes-Investment in mutual funds-Return not filed-Not responded to the notice-Alternative remedy-Writ petition is dismissed.[S. 10(26), 139(1),139(4C), 147, 148. Art. 226]

S. 143(3): Assessment-Order passed without giving assessee an adequate of opportunity of being heard-Order is not valid-The Assessing Officer is directed to pass an appropriate order as per law. [Art.226]

S. 143(3) : Assessment-Unexplained expenditure-Purchase of bullion/jewellery-Question of fact-Writ petition is dismissed.[S.69C, 144B,Central Goods and Service Tax Rules, 2017, Notification No. 12 of 2018 (Central Tax (2018) GSTR (St)1, Art. 226]

S. 143(3) : Assessment-Limited scrutiny assessment-Assessing Officer had initially issued notice under section 143(2) for a limited scrutiny on three aspects-Assessing Officer could not have expanded scope of scrutiny without prior to obtaining approval for a complete scrutiny from appropriate authority. [S.119, 143(2), 260A]

S. 119 : Central Board of Direct Taxes-Circular-Defective return-Genuine hardship-Lock down period-Delay in filing application for rectification of error committed in return of income is condoned. [S. 44ADA, 119(2)(b),139(5), 139(9), 154, Art. 226]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-
International transaction-Foreign exchange gains/loss-Operating income/loss is proper-Comparable-Exclusion of comparable is proper. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparable-Gains arising due to fluctuation in rate of foreign exchange-Income-safe harbour

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-
International transaction-Methods for determination of most appropriate method-Internal TNMM and not CUP method-Appellate authorities are not precluded from adopting a method different from that adopted by the assessee in the transfer pricing report-Order of Tribunal is affirmed-No substantial question of law. [S.260A]

S. 45 : Capital gains-Transfer-Part performance of contract-Joint development agreement-No accrual-Not registered-Ownership is retained-Possessing is parted for limited purpose of development-Not liable to be assessed as capital gains.[S. 2(47)(v),153A, 153C, Registration Act, 1908, S.17(IA), 49, Transfer of Property Act, 1882, S 53A]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Business expenditure-Commission paid to foreign agents on export of goods-Services rendered out side India-Not liable to tax in India-Not liable to deduct tax at source-No disallowance can be made [S. 9(1)(i), 37(1), 195, 260A]