S. 147 : Reassessment-After the expiry of four years-Change of opinion-No failure to disclose material facts-Mistake of Assessing Officer-Error discovered reconsideration of same facts does not give power to the Assessing Officer to reopen the assessment-Reassessment notice and order disposal of objection was quashed-Order of High Court affirmed. [S. 148, Art. 136]

S. 144C : Reference to dispute resolution panel-Mandatory proceedings-Draft assessment order proposing variations to returned income must be submitted to DRP–Order on remand must also be submitted to DRP-Not curable defects. [S. 92CA, 144C(2), 253(1)(d), 292B]

S. 144B : Faceless Assessment-Failure to issue show-cause notice or draft assessment order-Natural justice-Assessment orders set aside with directions for issue of show-cause notices or draft assessment orders, hear assessees and pass assessment orders afresh. [S. 143(2), 144C, Art, 226]

S. 144B : Faceless Assessment –Principle of natural justice-Failure to grant opportunity of hearing through Video conferencing-Order was set aside. [S.143(3), 144B(7), 263, Art. 226]

S. 144B : Faceless Assessment-Violation of the principle of natural justice-Unable to respond due to technical glitch-Order was set aside and matter remanded. [S. 143(3), Art. 226]

S. 143(3) : Assessment-Principle of natural justice-Guidelines for passing assessment order-Cash credits-2 G scam-Procedure for assessment laid down in Manual of office procedure issued by Directorate of Income-Tax must be followed-Assessing Officer must furnish to assessee all copies of documents referred to in order of assessment-Direction of the Tribunal must be followed-Prayer for one more opportunity to respondents was rejected-The assessment order was annulled. [S. 68, 254(1), Art. 226]

S. 143(1)(a) : Assessment-Intimation-Prima facie adjustment-Additional tax-Depreciation-Reduction of loss-Leviable only where attempt to evade tax proved-Department was to be set aside [S. 143(IA).

S. 92C : Transfer pricing-Arm’s length price-Selection of comparables-Functional dissimilarities and non-availability of segmental data-Finding of fact. [S. 92CA, 260A]

S. 80IB : Industrial undertakings-Manufacture of article falling under Eleventh Schedule-Polyurethane foam-Manufacturing polyurethane foam and supplying it in different sizes and designs to assembly operator for use ultimately for car seats-Not entitled to deduction. [S. 80IB(2)(iii), Sch. XI, Entry 25.]

S. 45(4) : Capital gains-Distribution of capital asset-Transfer-Dissolution of firm-Revaluation of assets and credit to capital accounts of partners-Introduction of new partners-Withdrawal of credit from capital account-Otherwise-Firm is liable to pay capital gains tax. [S. 2(47)(ii), 47(ii), 50]