S. 92C : Transfer pricing – Arm’s length price -Outsourcing its manufacturing activity – Advertisement , marketing and promotion expenses – Transfer pricing adjustment is not justified . [ S. 92B ]

S. 40(a)(ia): Amounts not deductible – Deduction at source – TDS was deducted on provision – Provision was reversed in next year – Parties are not identified – Addition for failure to deduct tax was held to be not justified [ S. 194J ]

S. 11: Property held for charitable purposes – Publishing newspaper – Denial of exemption is not justified [ S. 2(15),10(23C(iv)), 12A, 80G ]

S. 37(1):Business expenditure – Commission — Person who received commission confirming it by filing return of income — No evidence to show that money paid as commission has come back to assessee — Allowable as deduction .

S.147: Reassessment – After the expiry of four years – No failure to disclose material facts – What material facts are not disclosed is not pointed out -Notice and order disposing the objection was quashed. [S.147, 148, Art , 226 ]

S.147 :Reassessment – After the expiry of four years – Loan -Accommodation entries -Documents produced during assessment proceedings- No failure to disclose material facts- Notice and order disposing the objection was quashed . [S. 68, 148 , Art , 226 ]

S.148 :Reassessment – Order disposing the objection – Judgments relied upon by petitioner not applicable- Order disposing the objection was up held [S.147, Art , 226 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Assessing Officer cannot travel beyond show cause notice- CBDT Circular dated 11.5. 2022 applicable if amount of income which has escaped tax is less than Rs. 50 lakhs- Order was quashed .[ S. 148A(b), 148(A)(d), Art , 226 ]

S. 153A: Assessment – Search or requisition- Order was not barred by limitation – Seized material was handed on 27 -8 -2019 – Writ petition was dismissed- Directed to pursue alternative remedy . [S.153C(2) Art , 226 ]