S. 251 : Appeal-Commissioner (Appeals)-Powers-co-terminus powers with that of the AO-Revaluation of asset-Assessing the income under different head-Cash credits-Capital gains-Powers exercised by the CIT(A) cannot be said to be beyond the scope of provisions of s. 251(1)-What was considered by the CIT(A) is the very same income which arose out of the revaluation of the asset held by the firm. [S. 45(4), 68]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Revision-Revision order is set aside by the Tribunal-Issue subject matter of consideration or examination by a higher authority in the rank of hierarchy, the lower authority in the rank or the authority exercising equal powers cannot sit in judgment over the order passed by the higher authorities-The powers exercised by the CIT(A) under s. 251(1) to enhance the assessment towards consideration paid for purchase of property in the hands of the assessee is beyond the scope of the powers of the CIT(A)-Investment in purchase of property-Capital contribution by partners-Addition is deleted. [S.69, 153A, 251(1), 263]

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-Appeal-Non-disposal of rectification application within period of six months-Quantum od refund-AO is directed to entertain the said application under s. 154 and dispose it of as per law after verification of records. [S. 154(8),244A]

S. 154 : Rectification of mistake-Mistake apparent from the record-Order passed by the CPC without issuing any prior notice/intimation-Disallowance of PF /ESI-Jurisdictional High Court in favour of assessee-Adjustment is bad in law. [S.36(1)(va)]

S. 153C : Assessment-Income of any other person-Search-Recording of satisfaction-The documents were transmitted to the AO of the assessee, based on which he had rightly initiated the proceeding under S. 153C-The law is amendment of S. 153C w.e.f. 1st Oct., 2014-Incriminating material is found-Assessment is valid-Payment made to tenant is not in respect of said plot-Full consideration is assessable as income. [S. 132]

S. 148: Reassessment-Notice-Non-resident-Non jurisdictional AO-Revenue could not demonstrate that when the notice was issued on 30th March, 2022, ITO, Ajmer, had valid jurisdiction over the assessee-Reassessment is quashed.[S. 147]

S. 147 : Reassessment-Cash deposit-Substantial cash deposit-Return not filed-Reassessment notice is valid. [S. 68,115BBE, 148]

S. 147: Reassessment-Report of Investigation Wing-No tangible material-Reassessment is bad in law-Cash credits-Identity and creditworthiness is established-Addition is deleted. [S.68 148]

S. 147: Reassessment-Survey-Facilitating dubious transactions by accepting huge cash deposits from suspicious/unidentified entities and thereafter transferred most of these amounts to various other suspicious entities-Reassessment notice is valid.[S.133A, 148]

S: 145: Method of accounting-Project completion method-Advance from customers-Sale of 54 units-Neither sales were effected nor the possession of the flats were handed over to the purchasers during the relevant year-CIT(A) was not justified in sustaining the ad hoc addition of 10 per cent of the agreed value of the flats and also ad-hoc disallowance of common expenses. [S. 4, 37(1)]