S. 154 : Rectification of mistakes-Amalgamation of companies-Rectification for disallow claim allowed u/s. 80HHC is held to be not valid. [S. 80HHC]

S. 154 : Rectification of mistake-An order of rectification, on the basis of the law declared by the Supreme Court or the High Court is permissible-Non-resident-Shipping business–option to assessee- Interest can be levied. [S. 172, 234B, 234C]

S. 147 : Reassessment-Amalgamation of companies-Change of previous year allowed by AO-Reassessment proceedings on ground that AO was not aware of amalgamation of companies- Held to be not valid. [S. 148]

S. 147 : Reassessment-Notice-Order passed without disposing of objections raised by assesse-Reassessment Order is set aside to consider the objections.[S. 148]

S. 147 : Reassessment–Reasons for issue of notice must be given –Objections must considered by passing speaking order– Reassessment is held to be not valid-Existence of alternative remedy would not bar issue of writ. [S.148, Art. 226]

S. 127 : Power to transfer cases–Reasons must be recorded- Objections must be considered-Order of transfer is held to be not valid.

S. 119 : Central Board of Direct Taxes-Refund claims and carry forward the losses-Delay in filing of return-Refusal to condone the delay would cause genuine hardship to assessee-Rendering substantial justice is the paramount consideration of the Courts as well as the authorities rather than deciding on hyper technicalities.[S. 139(9)]

S. 115O : Domestic companies-Tax on distributed profits–Charging section–No need for issuance of notice before making a demand– Profits distributed to share holders is deemed to be dividend- Reduction on share capital can be effected by buying back shares –Advance Ruling cannot be given if an enquiry is pending against the assessee-Writ will not normally be issued if there is alternative remedy. [S. 2(22), 245R, Art.226]

S. 80IA : Industrial undertakings-Two manufacturing units-Deduction at 30% of eligible business–Not on total income.[S. 80AB]

S. 80IA : Industrial undertakings–Interest on bank deposits do not constitute business income for claiming deduction.