S. 147 : Reassessment–Foreign bequest–Request to transfer is pending-Bequest received by assessee at Sri Lanka could not be recognized as income–Reopening is held to be bad on law. [S. 2 (24)(iia), 5, 11(2), 12AA, 143(3), 148, 160(1)(iv), 161(1)]
S. 147 : Reassessment–Foreign bequest–Request to transfer is pending-Bequest received by assessee at Sri Lanka could not be recognized as income–Reopening is held to be bad on law. [S. 2 (24)(iia), 5, 11(2), 12AA, 143(3), 148, 160(1)(iv), 161(1)]
S. 145 : Method of accounting–Survey–Estimation of income on the basis of estimated gross profit on sales–Rejection of books of account without any reason-Addition is held to be not valid. [S. 133A, 144]
S. 143(2) : Assessment-Service of notice-Notice served on assessee which was not as per addresses as specified in rule 127(2) of 1962 Rules, assessment based on said notice is not valid assessment. [R. 127(2)]
S. 139 : Return–Invalid return-Failure to enclose the report from Chartered Accountant in Form No 3CEB–AO must give an opportunity to rectify the defect with in specified time-Reassessment is quashed on the ground of change of opinion. [S. 92E, 139(9), 147, 148, 271BA, ITAT R. 27]
S. 115JB : Book profit–Depreciation-Adjustment is held to be not valid. [S. 32, Companies Act, 1956]
S. 80IC : Special category States-Oil exploration activity can be taken as manufacture or production-Eligible for deduction. [S.80IB, 80IC(7)]
S. 80IB : Industrial undertakings–Eligible undertaking-Each oil well can be treated as a separate eligible undertaking–Not required to maintain separate account for each undertaking. [S. 80IC]
S. 72 : Carry forward and set off of business losses–Discontinued business-Entitle to set off the loss against business income of the current year. [S. 28(i), 71, 72(1), 176(3A)]
S. 69A : Unexplained money–Survey–Jangad stock–Stock register is supported by confirmation letter–Addition is held to be not valid.
S. 68 : Cash credits-Share application money–Premium-Confirmation filed-Mode of investment is explained–Addition is held to be not justified.