S. 147 : Reassessment-Alleged non conduct of Audit-Reassessment notice is not valid. [S 44AB, 80IB(11A), 133(6), 148]

S. 145 : Method of accounting-No adverse findings by the Chartered Accountant who has audited books of account-Estimation of net profit is not justified.

S. 145 : Method of accounting-Scrap sale-Estimation of profit-Survey-Not able to reconcile-Addition is held to be justified. [S.133A]

S. 144C : Reference to dispute resolution panel-Period of limitation has to be strictly followed-Order passed beyond period of limitation prescribed under section 144C(4)(b) of the Act is declared invalid. [S. 144C(4)(b)]

S. 144C : Reference to dispute resolution panel-Condonation of delay-DRP does not have power to condone delay in filing objections by assessee before Panel.

S. 143(3) : Assessment-Protective assessment-Income from other sources-No substantive addition was made in the other party-Addition was deleted. [S. 56]

S. 143(3) : Assessment-No direction of Appellate Tribunal to do fresh assessment-Passing remark by the Appellate Tribunal cannot be considered as observation of the Appellate Tribunal. [S. 254(1)]

S. 120 : Jurisdiction of income-tax authorities-Returned income less than of 30 lakhs-Jurisdiction of Assessing Officer-Assessment made by the Assistant Commissioner is without jurisdiction-Bad in law. [S. 127(1), 143(2), 143(3)]

S. 92C : Transfer pricing-Arm’s length price-Abnormal events-If an extraordinary event has taken place by way of amalgamation in a company, that company cannot be considered as a comparable-.R-elated party transaction of selected company exceeded limit of 25 per cent, said company be excluded from comparable list-turnover of selected company was almost 80 times more than turnover of assessee-company, said company could not be selected as comparable.

S. 92C : Transfer pricing-Arm’s length price-High Turnover-Huge intangible addition-Negative working capital-High turnover is a ground for excluding companies as not comparable with a company that has low turnover-Huge intangible assets-Could not be considered for inclusion in list of comparables to software development services provider.-Negative working capital adjustment shall not be made in case of a captive service provider as there is no risk and it is compensated on a total cost plus basis.