S.158BE: Block assessment – Limitation —Time taken to obtain information stored in Electronic records to be taken into account — Search started January 2001 —Access to records stored in computer was not given June 2001 — Block assessment In June 2003 — Not barred by limitation [ S. 132(1(iib) , 158BC , Information Technology Act , 2000 , S .2 ]

S. 153C : Assessment – Income of any other person – Search- Transfer of shares – Capital gains – Non compete fee- Price for which shares were sold was justified – Deletion of addition is held to be not justified [ S. 132, 143(3) 153A ]

S.153A: : Assessment – Search- Warrant of authorization – Application of mind and formation of opinion honest and bona fide belief- Issue of warrant of Authorisation and notice is held to be valid [ S.132 , Art. 226 ]

S.148: Reassessment —Notice – Pendency of assessment – Issue of notice for reassessment is not permissible [ S. 124(3), 142(1), 143(3), 147 ]

S.147: Reassessment —Share capital- Notice issued based on disallowances made in for subsequent year — No information available for specific assessment year – Notice is held to be invalid [ S.68 , 147(b) , 148 ]

S.147: Reassessment —Capital gains- Joint venture agreement with developer-Handing over possession of property and accepting refundable deposit — Matter Remanded to Assessing Officer. [ 2(47)(v), 45, 147, 148 , Transfer of Property Act 1882 , S.53A ]

S.147: Reassessment —Change of opinion- No new tangible material-Reassessment is held to be bad in law . [ S.148 ]

S.145: Method of valuation – Stock-In-Trade — Valuation —Encroached and litigated land — Cannot be valued at nil value — Remitting the matter to the Assessing Officer is held to be proper

S.145: Method of Accounting —Business of giving vehicles on hire purchase basis —Changing method of accounting to sum of digits but submitting returns on emi basis — Method is held to be proper

S. 144C : Reference to dispute resolution panel –Draft assessment order- Natural justice – Appellate Tribunal – Admission of additional evidence is held to be justified on question of law – When the Tribunal set aside the proceedings on the ground of violation of the principles of natural justice, the first exercise was void and without jurisdiction- Nothing remained on the record, including the draft assessment order-Issuance of a draft assessment order was necessary- Proceedings were to be started afresh on remand-.Non-issuance of the draft assessment order thus vitiated the final assessment order. [ S.92C, 254(1) ]