S. 142(2A) : Inquiry before assessment-Special audit-Opportunity of hearing was given-Writ to quash the special audit is dismissed-SLP of the assessee is dismissed. [S. 142(1)]

S. 127 : Power to transfer cases-Search operations-No incriminating material-No connection between the two entities-Transfer is invalid. [S. 132, Art.226]

S. 127 : Power to transfer cases-Cases transferred from E-assessment unit to Central Circle-Sanction of CBDT is not required as provided in E-assessment Scheme-Writ petition is dismissed. [S. 119, 143(3A), 143(3B), Art. 226]

S. 119 : Central Board of Direct Taxes-Instructions-Return-Delay of 21 seconds-Disallowance of claim under section 80IA-Delay was condoned. [S. 80IA, 119(2)(b), 143 (1), Art. 226]

S. 119 : Central Board of Direct Taxes-Instructions-Delay in filing of return-Application for condonation of delay was filed after 16 years-Delay was rejected-Writ petition was dismissed. [S. 119(2)(b), 139, Art. 226]

S. 115JB : Company-Book profit-Unabsorbed depreciation-Brought forward losses-Which evev is less as per books must be permitted. [S. 32]

S. 115AC : Capital gains-Bonds-Global Depository-Foreign currency-Transfer of Shares covered by scheme-Computation of capital gains to be made under provisions of scheme-Subsequent Amendment of provisions in Income-tax Act is not applicable.-Transaction not regarded as transfer-Capital gains-Transfer by way of conversion of bonds in to shares or debentures-Date of acquisition – Foreign currency bonds-Date of acquisition to be date of conversion of bonds into shares – Amendments in 2008 is not applicable – SLP is dismissed. [S. 2(42A) 47, 47(xa), 49(2A), Foreign Currency Convertible Bonds and ordinary Shares (Through Depository Receipt Mechanism) Scheme, 1993, Clause 7(4)]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-TNMM-CUP method-Payment of royalty-Determnetal to the interest of both assessee and Revenue-Addition was delted. [S. 260A]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Sale of software-Comparables-Segmental information was not available-Cannot be accepted as comparable.

S. 90 : Double taxation relief-Taxes deemed to have been payable-Eligible to tax credit- Tax payable -Income by way of dividend, received from its subsidiary in Thailand-Income deemed to accrue or arise in India-DTAA-India-Thailand. [S. 9(1)(i),9(1)(iv), Art. 23(3), 23(5)]