S. 144C : Reference to dispute resolution panel-Draft assessment order-Tribunal remanding the matter-Assessing Officer passing final order-Passing of draft order is mandatory-Order quashed and remanded. [S. 92CA(4), 143(3), 254(1), Art. 226]

S. 144C : Reference to dispute resolution panel-Arm’s length price-Remand by Tribunal-Order is valid-Entire procedure under section 144C need not be repeated. [S. 254(1), Art. 226]

S. 144B : Faceless Assessment-Natural justice-Final assessment order was passed before disposal of request for grant of time to file objections to draft assessment order-Order and notice was quashed. [S. 143(3) 156, 270A, 274, Art. 226]

S. 144B : Faceless Assessment-A notice-cum-draft assessment was to be issued and a personal hearing was to be accorded if there was variation in income-Notification issue by Central Board of Direct Taxes is binding on department-Order was set aside. [143(3), Art. 226]

S. 115JB : Book profit-Amendment in Law-Explanation 3-Not Applicable.

S. 115A : Foreign companies-Tax-Royalty-Different agreements-The assessee can opt to be either under statutory provisions or the Double taxation avoidance agreement-DTAA-India-USA [S.90]

S. 80IA : Industrial undertakings-Loss-Setting off of Loss of loss-making units against profits of profit-making units-Entitle to benefit.

S. 50D : Fair market value deemed to be full value of consideration in certain shares-Non-Resident-Capital gains-Sale of share-Not slump sale-Capital gains chargeable to taxable ten percent. [S. 45, 55A, 56(2)(viia), 112(1)(c)(iii)]

S. 50 : Capital gains-Depreciable assets-Block of assets-Depreciation allowed for 21 years-Not used for business for two years-Asset shown as investment in balance sheet-Gains assessable as short term capital gains. [S. 2(11), 2(29A), 2(29B) 45, 50A]

S. 43B : Deductions on actual payment-Interest payable to Financial Institutions-Rehabilitation plan and accepting debentures in discharge of outstanding interest-Explanation 3C, cannot be invoked-Interest is allowable as deduction-Interpretation of taxing statutes-Retrospective provision for the removal of doubts Cannot be presumed to be retrospective if it alters or changes law as it stood-Ambiguity in language to be resolved in favour of assessee. [S.43D]