Reopening of assessment requires fresh tangible material showing escaped income; identical adjudicated transactions cannot be reassessed.

Notice of Demand under Section 156 invalid without antecedent assessment or reassessment; reopening under Section 147 required.

Fees for technical services: Article 9 neutralisation cannot recharacterise intra-group refurbishing fees; not taxable in India.

Genuineness of investment evidence determines LTCG entitlement; non specific regulatory reports cannot displace transaction specific documentary proof...

Audit Report Requirement: proviso applied from cut-off date, mere CA certificate insufficient and penalty for non-filing upheld.

Undervalued property under Section 56(2)(vii) - remanded for AO to verify books, CBDT guidance and afford hearing.

Transfer Pricing methods: Bright Line Test rejected; limited ALP uplift ordered using adjusted TNMM comparability margin.

Substantial justice over technical non compliance: non deliberate delay in Form 10CCB cannot deny a valid start up tax exemption.

Books of account rejection required before estimation; estimated additions quashed where AO accepted the books and yet made independent estimates.

Excessiveness under section 40A(2) must be found; lack of minute employee details alone cannot justify disallowance.

Goodwill Depreciation disallowed as artificial creation; buy-back distributed-income tax sustained and valuation rejected on related-party transaction...

Revenue v Capital classification: temporary, site-specific works that yield no enduring business benefit are revenue expenditure, not capital.

Reopening of assessment invalid where assessing officer fails to record reasons or apply mind; reassessment notice quashed.

Limitation period for penalty under section 275(1)(c) bars late imposition; corroborative evidence required for 271DA penalties.

Application of benefit-test and connected-persons rejected where no direct or indirect benefit; disallowance limited to the short-applied year.

Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...

Private benefit rule failed where documentary possession and no personal gain established, so charitable exemption sustained.

Transfer Pricing: internal CUP accepted, forex risk add on rejected and multiple adjustments deleted in favour of the taxpayer.

Voluntary deposit prior to notice leads to deletion of penalties when excess refund is repaid and revised return filed.

Rejection of books of accounts upheld; unexplained cash deposits during demonetisation deleted where sales explain bank deposits.