S. 263 : Commissioner – Revision of orders prejudicial to revenue –Development agreement- Transfer and right to possession of developer does not arise prior to completion of construction and apportionment effected- Quantum of depreciation based on facts -Revision was held to be not valid . [ S. 2(47(v), 32, 45, Transfer of Property Act, 1953 S. 53A ]

S. 153 : Assessment –Limitation – When seven issues were before Tribunal, Tribunal remanding of only five issues- Time Limit specified in S.153(2A) is applicable not S.153 (3)(ii)of the Act-Order is held to be not valid .[ S. 153(2A), 153(3)(ii) ]

S.147: Reassessment —Reassessment notice issued would remain in operation unless it is specifically withdrawn, quashed or gets time barred Subsequently- Subsequently Assessing Officer desired to withdraw of notice without issuing any formal withdrawal of notice — The law does not recognise two parallel assessments- In the absence of withdrawal of the first notice of reassessment, the proceedings would survive -Second notice of Reassessment is held to be not valid.[ S.148 ]

S.69: Unexplained Investments — Unexplained Cash — Construction of building –Withdrawal from bank and redeposit-Explanation was not satisfactory- Addition as unexplained investments is held to be justified .[ S.69A ]

S. 68 : Cash credits -Receipt towards payment for Contract cannot be assessed as unexplained cash-simply because notices could not be served upon the sub-contractor, the transactions could not be held non-genuine .

S. 68 : Cash credits – Share application money – Persons of insignificant means — Neither the creditworthiness of the creditors nor the genuineness of the transaction stood explained- Order of Tribunal up holding addition is confirmed .

S. 54 : Capital gains – Profit on sale of property used for residence -Construction of residential house – Cost of land is also form cost of residential house –Not necessary that same money from sale of residential asset must be used .[S. 45 ]

S. 48 : Capital gains – Property inherited under Will — Amount paid for discharge of encumbrances —Allowable as deduction .[ S. 45, 55 ]

S.40(a)(ia):Amounts not deductible – Deduction at source –
Payment of labour charges through labour contractor — No contract between assessee and sub-contractor — Not liable to deduct tax at source-No disallowance can be made .[ S.194C ]

S. 37(1) : Business expenditure –Capital or revenue- Business carried on leased premises – Expenditure on repairs and refurbishing is revenue expenditure — Expenditure on erecting structures —Matter remanded – The court also directed that since the lease deeds produced before the court were not registered the Deputy Commissioner was to impound the documents and refer them to the District Registrar for proper stamping and the assessee would also be obliged to register the deeds. [ S.32(1)]