S. 144C : Reference to dispute resolution panel-Assessing Officer passing final assessment order before Transfer Pricing Officer gave effect to directions of Dispute Resolution Panel-Final assessment order rectified on application of assessee after Transfer Pricing Officer gave effect to directions-Rectified final assessment order deemed to be within limitation-Final assessment order is valid. [S. 144C(13), 154]

S. 143(3): Assessment-Accommodation entries-Bogus purchases-Sales accepted-Only profit element embedded in alleged bogus purchases can be added and not value of purchase.[S. 5]

S. 143(3): Assessment-Jurisdiction-Central Board of Direct Taxes, by its Instruction No. 1 of 2011, dated January 31, 2011-Monetary limits-Vest with ITO-Notice under section 143(2) is issued by the Deputy Commissioner is not valid-Assessment is quashed. [S.119,120, 143(2)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Functionally different-Comparable to be excluded-Paying Technical support service fees to Associated Enterprise-Matter remanded–External commercial borrowings-Adopting Arm’s Length interest rate as per Master Circular of Reserve Bank of India-Transfer Pricing Officer adopting rate based on Libor-Adjustment upheld-Interest cost-Interest On Overdue Receivables from Associated Enterprises-Receivables constitute international transactions-Transactional Net Margin Method-Net Margin computed would consider interest cost-Addition is deleted-Expenses reimbursed-Addition upheld in absence of evidence. [S.92CD]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Comparables-Business process outsourcing services and doing actual work based on specifications provided by Associated Enterprises-Company functionally different and not comparable to be excluded–Extraordinary event of acquisitions renders is not comparable. [S.92C(3)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Reimbursement of expenses on actual-cost basis-Meeting of statutory duties, fees and other charges-Adjustment is not valid. [S.92CA]

S. 68 : Cash credits-Unexplained sundry creditors-Summons issued to creditors returned-Unsigned copies of ledger accounts-Confirmations signed only by assessee and not by creditors-Matter remanded. [S. 131(1)(d)]

S. 68 : Cash credits-Unaccounted money-Substantial addition is made-Deletion of addition is justified.

S.54F : Capital gains-Investment in a residential house-Monthly tenancy-Owner entering into development agreement –Development of building-Two flats in new building is allotted to assessee and spouse-Market value as consideration-Relinquishment of tenancy rights in lieu of allotment of new flat-Entitle to exemption –Power of Tribunal-Death of the assessee during pendency of appeal-Tribunal has the power to decide the appeal on the relevant material [S. 45, 254(1), ITAT R.1963, R.26]

S. 43(1) : Actual cost-Depreciation-Amalgamation of Banks Amalgamating Bank Ceases To Exist-Tribunal Right In Allowing Depreciation On Assets Taken Over Pursuant To Amalgamation With Assessee [S. 32, 43(1), Explanation 7]