S. 153A : Assessment–Search-Share application money–No incriminating material was found–Addition cannot be made–Opportunity to cross examination must be given of the entry operators. [S. 68, 132]

S. 153A : Assessment–Search-No incriminating material was found-Addition cannot be made. [S. 68, 132]

S. 153 : Assessment–Limitation–Special audit under section 142(2A) is not in accordance with law, time limit for making assessment cannot be extended for time taken for special audit. [S. 142(2A)]

S. 151 : Reassessment-Sanction for issue of notice-Share capital-Share premium-Approval-mechanical approval mentioning “Yes”–Non application of mind – Reassessment is held to be bad in law. [S. 147, 148]

S. 151 : Reassessment-Sanction for issue of notice–Sanction by CIT instead JCIT–Reassessment is held to be bad in law. [S. 147, 151]

S. 148: Reassessment – Notice – Notice has been issued on wrong premise, reopening of assessment is not valid-Notice cannot be issued for certain examination [ S.147 ]

S. 147 : Reassessment –With in four years-Reopening for taxing Bogus share capital-Even in a S. 143(1) intimation, the AO is not entitled to reopen on the ground that the assessee has received “huge share premium” which was not “examined” by the AO. The AO cannot reopen in the absence of tangible material that shows income has escaped assessment. [S. 68, 143(1)]

S. 147 : Reassessment-Reasons for reopening was communicated to assessee –No objections made by assessee-AO assumed valid jurisdiction-Reassessment is held to be valid. [S. 148, 151]

S. 145 : Method of accounting-Estimation of income-Accounts of assessee were subject to statutory as well as tax audit–Accounts not rejected-Addition made on estimate basis was deleted.

S. 145: Method of accounting De-reorganisation was done for default on part of customers; thus, change in method of account was on account of proper reasons, AO was not justified in rejecting the books without finding any fault with such change.