S. 251 : Appeal-Commissioner (Appeals)-Powers-Enhancement by Commissioner (Appeals)-Mandatory notice under section 251(2) not issued-Enhancement invalid-Company-Book profit-Recast financial statements-Adjustment not adjudicated-Matter remanded. [S. 115JB, 251 (2)]

S. 194C: Deduction at source-Contractors-Rent-Common Area Maintenance (CAM) charges-Separate agreements-CAM charges not part of rent-Tax deductible under section 194C at 1% and not at 10% u/s 194I. [S. 194I, 201(1), 201(1A)]

S. 153C: Assessment-Income of any other person-Search–Third-party search-Dumb document-Abbreviated entries without corroborative evidence-Addition deleted-Limitation-Satisfaction note received beyond permissible period-Assessment for assessment year 2015-16 without jurisdiction-Satisfaction note-Prima facie satisfaction sufficient for assumption of jurisdiction-Delay of 16 days-Sufficient cause-Delay condoned.[S. 132(4), 153A, 292C]

S. 153A: Assessment-Search-No incriminating material found during search of assessee-Material seized from third party cannot form basis of assessment under section 153A-Assessment invalid-Return filed in response to notice-Revised computation during assessment-Addition based on difference from original return-Not justified-Undisclosed income-Sale of plots-Transactions duly recorded in books-No evidence of suppression-Addition deleted-Unexplained expenditure-Development expenses-Assessee only landowner-Expenditure incurred by associates-Addition deleted-Cash credits-Sale proceeds of plots deposited in bank-Source explained-Enhancement of profit by Commissioner (Appeals) deleted-Inter-bank transfer-Amount taxed twice as unexplained credit-Addition deleted-Cash credits-Documentary evidence explaining source-Addition restricted to profit element upheld. [S. 68, 69, 69C, 132, 139 153C]

S. 153A: Assessment-Search-Unexplained investment-Addition based solely on retracted statement-No corroborative evidence-Addition deleted-Rental income-Seized rental agreement-Income already offered to tax-Addition deleted-Unexplained investment-Cost of construction-Addition based only on retracted confession-No supporting evidence-Addition deleted.[S. 69, 132(4), 153D]

S. 149: Reassessment-Time limit for notice-Notices under new regime issued beyond limitation prescribed by Supreme Court-Proceedings time-barred-Withdrawal of approval under section 10(23C)(vi) invalid-Second proviso-Applicable only from assessment year 2022-23-Reference to Principal Commissioner for earlier years invalid-Withdrawal of approval-Jurisdiction-Reference made to wrong authority-Order without jurisdiction.[S 10(23C)(vi) 148, 148A(b), 148A(d)]

S. 148: Reassessment-Non-resident-Notice issued by non-jurisdictional Assessing Officer-Assessment framed by Assessing Officer (International Taxation) on same notice-Reassessment void-Delay of 57 days was condoned. [S. 147, 254(1)]

S. 145: Method of accounting-Percentage Completion Method-Consistently followed and accepted-Revenue cannot substitute completed sales method without pointing out defects-Percentage Completion Method-Double taxation avoided-Addition deleted.

S. 143(2): Assessment-Notice-Return filed in response to notice under section 148 not e-verified-Return non est-Notice under section 143(2) not mandatory.[S. 139, 148]

S. 92C: Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Adjustment to be confined to international transactions with Associated Enterprises–Comparables-Functional similarity-Government company not to be excluded merely because of Government ownership-Matter remanded-Trading segment-Commission earned on direct sales by Associated Enterprises to third-party customers-Not part of trading activity-Transactional Net Margin Method-Global sales and marketing expenditure-Operating cost.[S.92CA]