S. 69 :Unexplained investments -Peak credit – Amount disclosed and offered in one assessment year – Revenue bifurcating in to two assessment year – Rate of tax in same in both assessment year – Appeal of Revenue dismissed as there is no loss to Revenue . [ S. 132(4)]

S .14A : Disallowance of expenditure – Exempt income – Dividend income from overseas company in Oman – No tax is payable on said dividend in India- Provision of section 14A is not attracted – DTAA -India – Oman .[ S. 2(45), 5,90(2)) R.8D , Art , 25 ]

S. 276B : Offences and prosecutions – Failure to pay to the credit tax deducted at source -Compounding application – Failure to dispose the compounding application by the Principal Commissioner – Directed the Principal Commissioner to dispose the pending compounding application with in the period of three months from to day and not later than 27 th February 2023 . [ S. 204 ,278B ,279(2)), Art , 226 ]

S. 68: Cash credits – Foreign bank deposits – HSBC account – Non -Resident – Merely on the basis of ‘base note’ addition cannot be made in the hands of non -Resident – Deletion of addition is affirmed . [ S. 5(2), 6 , 147, 148]

S. 148 : Reassessment –Notice – Reasons recorded not furnished – Directions issued to Department to furnish the reasons recorded [ S. 147, Art , 226 ]

S. 147 : Reassessment –With in four years- Reason must be based on tangible material —Change of opinion -Assessment order did not mention these issues not material — Reasons cannot be improved or supplemented or substituted by affidavit or oral submissions- Notices and order rejecting objections quashed and set aside .[ 142(1), 143(2), 148 , Art , 226 ]

S. 144C: Reference to dispute resolution panel – Transfer pricing – No variation in Arm’s Length Price – Barred by limitation – No draft order as assessee is not an “eligible assessee” – Draft order and final assessment order is quashed. [ S.92CA(3), 144C(15)(b) ]