S. 271(1)(c) : Penalty-Concealment-Not specifying the limb of section-Penalty proceedings is not sustainable. [S. 274]

S. 271(1)(c) : Penalty-Concealment-Arm’s length price-Adjustment of transfer pricing-Disallowance of expenditure-Penalty not leviable.

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Substantial expansion-Initial assessment year-Order not erroneous-Revision was held to be not valid. [S. 80IC]

S. 154 : Rectification of mistake-Intimation-Not reporting income in proper columns-Double taxation-Income cannot be taxed twice-Matter remanded-DTAA-India-United Kingdom. [S. 143(1), Art. 13]

S. 153C : Assessment-Income of any other person-On money-Settlement Commission-Firm admitting that the surplus belong to the firm and related parties-Amount credited to partner’s account-Deletion of addition is held to be justified. [S. 132]

S. 147 : Reassessment-No fresh tangible material-Reassessment not valid. [S. 143(1), 148]

S. 147 : Reassessment-Compensation received-No discussion in the assessment order-Reassessment was up held. [S. 28(va), 148]

S. 147 : Reassessment-With in four years-Information from Investigation Wing-Client code modification-Mistake by share broker-Reassessment is held to be not valid. [S. 148]

S. 147 : Reassessment-After the expiry of four years-Unexplained investment-Beneficiaries of Trusts-Discretionary trust-Account with bank in Liechtenstein-Notice barred by limitation-Addition was not valid-1/5 share in the trust neither accrued nor arisen-Additional ground was admitted. [S. 69, 143(3), 148, 151(2)]

S. 145 : Method of accounting-Real estate business-Project competition method-Advance from customers-Estimate at 10 percent of advance received during the year is proper-Advance carried over from earlier years no addition can be made. [S. 28(1), 145(3)]