S. 153A : Assessment–Search-Pending assessment abate–Order is set aside to determine the income as per S. 153A of the Act. [S.132, 143(2)]
S. 153A : Assessment–Search-Pending assessment abate–Order is set aside to determine the income as per S. 153A of the Act. [S.132, 143(2)]
S. 153A : Assessment–Search or requisition-Unaccounted sales- Seized documents containing both accounted as well as unaccounted sales-No material on record suggesting sales made over and above sales recorded in seized documents-Addition to be confined to income from unaccounted sales recorded in seized documents search and seizure.
S. 153A : Assessment-Search or requisition-income from undisclosed sources-excess stock-waste included by assessee in stock of yarn-department treating it as fresh yarn and making addition–Addition is held to be not valid.
S. 148 : Reassessment–Notice-reopening against assessee-firm on basis of order on appeal in case of partner of assessee-reassessment to bring to tax in hands of firm sum wrongly taxed in partner’s hands-limitation to be considered as on date of passing assessment order in partner’s hands. [S. 147, 149, 150(1)]
S. 147 : Reassessment-Order passed without disposing the objections–Order is bad in law. [S. 148]
S. 147: Reassessment-Assessment made in the name of a non-existing entity is void and liable to be quashed-Jurisdictional defect cannot be cured-Mere participation by the Assessee had no effect as there can be no estoppel against law. [S. 148, 292B R.27]
S. 147 : Reassessment—After the expiry of four years-Assessing officer not analysing details of expenditure while forming belief that income had escaped assessment-No specific expenditure could be termed as incurred exclusively for personal needs of assessee — Completed assessment of assessee after four years could not be reopened [ S.148]
S. 145 : Method of accounting-Construction business-Project completion method-Consistently following the method-Department should accept the method.
S. 143(3) : Assessment–Accrual of income-Year of taxability–Rate of tax-The income was offered in the subsequent year (basis the billing done), tax rate being the same, interest of revenue was not affected, therefore income could not be taxed on accrual basis in the current year. [S. 2(24), 5]
S. 92C : Transfer pricing-Arms’ length price-Failure by authorities to follow procedure prescribed-Matter remanded. [R. 10B]