FERA show-cause notices after repeal were quashed for lack of jurisdiction under the FEMA savings scheme

Composite show cause notices covering multiple assessment years are unsustainable; separate notices and limitation exclusion follow.

Advertising contract classification for Google AdWords payments prevailed over technical services treatment, so Section 194C TDS applied.

Cost-to-cost reimbursements and LIBOR-based receivables interest were accepted, with withholding and transfer pricing additions deleted.

Discounted cash flow share premium valuation and no-exempt-income rule: additions deleted, with prospective amendment held inapplicable

Territorial jurisdiction of Assessing Officer: notice by a non-jurisdictional officer held invalid, assessments quashed.

Adequate enquiry bars revision under section 263 where trust advance to a specified person was examined

Cross-examination and corroboration defeat penalty for alleged cash loan based only on third-party statements and loose papers.

Under-reporting penalty and 14A disallowance deleted where the notice was wrongly framed and no exempt income existed

Fair market value under section 50C must reflect existing property condition, not hypothetical development, and statutory valuation steps must be foll...

Search assessment additions require incriminating material; estimated stock and third-party ledger claims failed, while limited profit addition surviv...

Bank tax deductions and depreciation claims upheld as unrealised forex gains and MAT challenges failed entirely

Section 10AA deduction and reassessment scope: partner remuneration omission and unrelated additions were both held unsustainable

Protective addition and commission income fail where cash and profit were owned up by others; seized gold requires verification

ESOP discount deduction and no-exempt-income rule under section 14A supported deletion of tax disallowances.

Reopening after scrutiny assessment fails where recorded reasons rest on a false premise and show non-application of mind

Uncorroborated search material cannot sustain protective additions when seized papers lack corroboration and no fresh evidence emerges.

Section 153C jurisdiction turns on receipt of seized material date, not searched person's search date, for other person assessments.

DSIR-approved R&D deduction and APA-aligned transfer pricing adjustments were limited, while double disallowance was rejected.

Condonation of initial non-compliance with assessment notices bars penalty where later replies are accepted in assessment.