S.147: Reassessment —With in four years-Change of opinion- Claim of exemption was accepted in original assessment after scrutiny – Reassessment to withdraw Exemption on ground that some other aspects of claim was not examined will be change of opinion which is not permissible . [ S.10S, 10B, 148, 264 ]

S.147:Reassessment —with in four years- Change of opinion -Opinion of revenue Audit party- Foreign Exchange Fluctuation gain on interest income is not allowable — Notice for reassessment is held to be invalid [ S.148 ]

S.147: Reassessment —With in four years -Reasons for notice must be communicated-Failure to communicate the reason is not procedural lapse, it goes to the root of the matter – Mere participation of the assessee or authorised representative in the reassessment proceedings does not amount to the assessee being made aware or known of the reasons for such reopening- order is not valid. [ S.148 ]

S.147: Reassessment —With in four years -Cash credit — Capital – Partner- Return was not filed – No specific direction by CIT(A)- Notice for reassessment was held to be valid . [ S.68, 148 ]

S.147:Reassessment –With in four years-Change of opinion- Block assessment -Notice to reassess amount discovered during post search enquiries is held to be not valid . [ S.132,148, 158BC ]

S. 145A : Method of accounting – Valuation -Stock- Trading in shares — Valuation of shares according to net realisable value is held to be justified .[S.145(2) ]

S. 80-O : Royalties – Foreign enterprises -Fees for technical services rendered to foreign entity — Explanation added with effect from 1-4-1992 — Fees for services rendered in India- Not entitled to deduction – Principle of consistency or doctrine of precedents would not apply when there is change in law.

S. 80IC : Special category States -Initial Assessment Year —Substantial expansion- Claimed 100% deduction for five years- Cannot claim deduction at 100 Per Cent. beyond period of five years on ground of substantial expansion.

S. 45(4) : Capital gains – Distribution of capital asset – Dissolution of firm -Change in constitution of firm -Retirement of some partners and induction of new partners — No revaluation of assets — Businesses continued — Firm reconstituted and not dissolved-Not liable to pay capital gains tax . [ S. 45,187(2) ]

S.37 (1): Business expenditure —Travelling expenditure of wife of Company’s Senior Executive accompanying him abroad for his medical treatment — Expenditure is held to be not allowable . [ S.264 ]