S. 148 : Reassessment-Notice-Amalgamation-Company ceased to exist-Authorities are aware of amalgamation-Notice is held to be not valid. [S. 147, Art. 226]

S. 147 : Reassessment-With in four years-Transaction has not taken place in previous year-Objection is not considered-Sanction is without application of mind-Notice and order disposing the application is quashed.[S. 133(6), 148, 151, Art. 226]

S. 147 : Reassessment-With in four years-Audit objection and factual errors-Capital gains-Agricultural land-Notice is bad in law-Notice and order is quashed. [S. 45, 50C, 148, Art. 226]

S. 147 : Reassessment-With in four years-Borrowed satisfaction-change of opinion-Notice without jurisdiction-Notice and order disposing the objection is quashed-Writ can be entertained on judicial aspect. [S. 2(40) 142(1), 143(2), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No evidence of failure to disclose material facts-Notice not specifying which facts not disclosed-Reassessment notice and order disposing the objection is quashed. [S. 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Sales promotion expenses-Gift expenses-Health care professionals-Change in law subsequently-Reassessment notice and order disposing the objection is quashed. [S. 148, Art. 226, Medical Council of India Act, 1956, The Indian Medical Council (Professional Conduct, Etiquette and Ethics) Regulations, 2002.]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Benchmarking to be done for only associated enterprises’ transactions and not for entire turnover-Order of Tribunal is affirmed. [S. 260A]

S. 90 : Double taxation relief-Agreement or Protocol entered into by Government-Enforceable in courts and Tribunals only after appropriate notification-Most favoured nation-No right to invoke most favoured nation clause when third country with which India has entered into Double Taxation Avoidance Agreement was not yet member of organisation for economic co-operation and development at time of entering into such agreement-Most favoured nation clause comes into effect after notification is issued-DTAA-India-France-Netherlands-Switzerland-Words and Phrases-“Is”-Interpretation-Double taxation Avoidance agreements. [S. 90(1), Art. 73]

S. 45 : Capital gains-Agreement for joint development of land-Giving power of attorney to land owner-No conveyance in year of agreement-No liability to capital gains tax in the year of development agreement.[S. 2(47)]

S. 45 : Capital gains-Land-Joint Development Agreement-Possession of land only for purposes of development-No transfer of land in 2008-Order of Tribunal is reversed. [S. 2(47)(v), Transfer of Property Act, 1882, S. 53A]