S. 147 : Reassessment- Change of opinion- Export receivables could be written off during the pendency of the application for approval from the Reserve Bank of India- Claim of bad debt was allowed after scrutiny – Reassessment is held to be not valid .[ S. 36(1)(vii) ,148 ]

S. 147 : Reassessment -Export business- No new material- Notice under direction of Commissioner-Reassessment is held to be not valid. [ S80HHC, 148 ]

S. 143(3) : Assessment – Matter remanded by the Tribunal with the direction to grant an opportunity of cross examination- Not giving an opportunity of cross examination – Writ against the order is not maintainable – Issue could be raised in appellate Proceedings . [ S. 35(1) (ii), 246A(1)(a), 250(4) , 254(1) Art .226 ]

S. 64 : Clubbing of income – Minor child – Provision coming into force with effect from 1-4-1976 cannot be given retrospectivity and be made applicable to previous accounting year 1975-76 corresponding to assessment year 1976-77 [ S. 64 (1) (iii) ]

S. 54F : Capital gains – Investment in a residential house –Transfer includes extinguishment of rights – Agreement to sell land and purchaser given possession in August 2010 — Sale deed executed in July 2012 — Purchase of residential house in April 2010 —Entitled to exemption. [ S.2(47)iii) , 45,54F ]

S. 54B : Capital gains – Land used for agricultural purposes – No proper finding regarding character of land – Matter remanded . [ S. 45 , 254(1), Bombay Tenancy and Agricultural Lands Act , S. 43, 63 ]

S.40(a)(ia):Amounts not deductible – Deduction at source –
Amendment to S.40A(ia) by Finance Act, 2010 permitting deposit of tax deducted at source till due date for filing return is retrospective in operation. [ S 139(1),260A ]

S. 36(1)(viia) :Bad debt-Provision for bad and doubtful debts – Schedule bank -Bad debts written off in accounts is deductible – Determination of Rural branch is to be based on revenue records .

S. 14A : Disallowance of expenditure – Exempt income – Section is not retrospective in operation – Not applicable prior to assessment year 2008 -09.

S. 14A : Disallowance of expenditure – Exempt income -Remand by the Tribunal is held to be valid- Ad hoc disallowances cannot be made – The court granted liberty to the assessee to raise the contention with regard to the jurisdiction of the Assessing Officer to invoke section 14A(2) .[ S.254(1) , R.8D ]