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    Assessing Officer lacks jurisdiction to reopen assessment when show-cause notices are mere fishing inquiries without live nexus to sale deed
    PAN-based ITBA migration error cannot replace statutory transfer order under s.127; electronic records do not confer jurisdiction
    Reassessment under s.153A quashed; documents treated as business records, no transfer under s.2(47), assessment restored
    S.154 rectification upheld, restoring assessee's s.10(23D) exemption for SEBI-registered mutual fund income after CPC acceptance
    Assessee wins: s.56(2)(viia) targets unappropriated shares, not bona fide fresh allotments; valuation and other additions deleted
    TDS credit be given to employee despite employer's CIRP moratorium under IBC s.9; AO directed to grant within 60 days
    Delayed filing of revised Form 10DA is a procedural lapse; deduction under section 80JJAA allowed, remitted for verification and quantification
    s.153D approvals invalid where omnibus mechanical sanction without independent reasoning; assessments quashed for lack of application of mind
    Section 54F(2): 'Purchase' broadly construed; allow pro rata exemption when new house cost is less than net sale consideration
    Assessment orders 29.12.2017 void ab initio as time-barred; no proof of dispatch under s.153B, breach s.282/Rule127
    Assessing officers cannot rely solely on software-generated PAN data; proceedings against merged, deceased entities unjustified, costs reduced
    Telescoping set-off of Rs.86,15,72,422 allowed; alloy making charges accepted, specific additions totaling Rs.13.59 crore sustained
    Proceedings under section 153C invalidated where AO's satisfaction note failed to identify documents, link years, or quantify seizures.
    Unilateral APA applied to AY2013-14 for AMP reimbursement; TDS under s.195 and disallowance u/s 40(a)(i) remitted for re-verification
    2,455-day delay excused as reasonable cause; matter restored for limited TDS verification; Section 234E fees adjusted
    Reopening under s.148 upheld but s.251(2)/s.145(3) substantive additions set aside; s.12AA cancellation not sustained in appeal
    Tax on section 69A additions must be calculated at 30% under pre-amendment section 115BBE, reassessment directed
    Agent entitled to full TDS credit if reflected in Form 26AS under s.199(3) read with r.37BA
    Transfer pricing comparability remanded for rework after TPO used lower turnover filter without upper turnover limit
    Transfer pricing remanded for fresh benchmarking; proviso to s.36(1) interest allowed as revenue; advertisement expense held revenue
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Acts Income Tax