S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Approval by Principal Commissioner invalid-Reassessment quashed [Ss. 147, 148, 148A(b), 151(i), 151(ii)]

S. 147 : Reassessment-Vehicle hiring charges-Specific query was raised in the assessment proceedings-Reassessment is quashed. [S. 11, 13(1)(c), 13(3)(cc), 143(3)]

S. 147: Reassessment-Industrial undertakings-Lower deduction in original return-Higher deduction in response to notice u/s 148-Deduction cannot be denied. [S.80IA, 148]

S. 147 : Reassessment-Information from DIT (Inv)-Beneficiary of accommodation entries-Long term capital gains-Sale of shares-Vague reasons recorded-Borrowed satisfaction-Sanction-Mechanical approval-Reassessment was quashed. [S.69A, 143)(1), 148, 151]

S. 144C : Reference to dispute resolution panel-Revised direction of DRP-Rectification order-Assessing Officer is directed to consider rectified direction of DRP and corresponding revised giving-effect order of TPO and delete entire TP adjustment. [S.92C, 154]

S. 143(3) :Assessment-limited scrutiny-Disallowance of expenditure-Exempt income-Suo moto disallowed the expenditure-Not part of reasons for limited scrutiny-Capital gains-Short term loss-Suo moto disallowed the expenditure-Disallowance made by the Assessing Officer is deleted. [S. 14A, 28(i), 45, 143(3), R. 8D]

S. 143(3): Assessment-Non existing company-Merger-Assessment was invalid and quashed. [S. 170]

S. 143(1) : Assessment-Intimation –Payment of bonus-adjustment made under section 143(1) was incorporated in assessment framed under section 143(3) without taking into cognizance of adjustment made by CPC in intimation-Matter is set aside to file of Assessing Officer for fresh adjudication as per provisions of law.[S. 143(3)]

S. 92B : Transfer pricing-International transaction-Arm’s length price-Avoidance of tax-Interest on outstanding receivables is an international transaction-Separate benchmarking-Appropriate rate of interest would be LIBOR + 200 basis point. [S.92C]

S. 90 :Double taxation relief-Filing of Form No. 67 read with rule 128 is only directory in nature and not mandatory-Belated filing of Form No. 67 would not bar claim of Foreign Tax Credit (FTC)-Dividend income from USA based company-Rate of tax on said income is already prescribed under India-USA DTAA, same shall prevail over and above normal tax rate provided under Income-tax Act-DTAA-India-USA. [S. 143(1)(a), Art. 10, 25, R. 128, Form No 67]