S. 148 : Reassessment–Notice–Reply stating that original return filed should be treated as return filed in repose to notice u/s. 148-Postal receipt is filed–Neither notice u/s. 143(2) is issued nor assessment completed u/s. 144 of the Act nor interest charged u/s. 234A–Reassessment is held to be not valid. [S. 139, 143(2), 144, 147, 234A]
S. 147 : Reassessment-Reason to be believe-Securities premium account–Merely on the basis of information received by another AO based on appraisal report of A group-Reassessment cannot be made. [S. 148]
S. 147 : Reassessment-Falsification of accounts–Statement of chairman–Un explained loans–Interest-Reassessment is held to be valid–Order of CIT(A) is affirmed. [S. 2(22)(e), 148]
S. 147 : Reassessment–With in four years-Depreciation at higher rate-Not examining the issue at the time of original assessment– Reassessment is held to be valid. [S. 32, 143(1)]
S. 147 : Reassessment–With in four years-Search and seizure– Alleged cash loans–Parties denying cash loans-Reassessment is held to be nor valid–Correct legal course could have been action u/s. 153C and not reassessment–Addition is deleted. [S. 132, 153A, 153C, 148]
S. 147 : Reassessment-After the expiry of four years-Survey– Difference of labour charges-No failure to disclose material facts-Reassessment is held to be not permissible. [S. 133A, 148]
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts–CIT granting two approvals of the same recorded reasons-Reassessment is held to be bad in law–Seized material not containing any incriminating materials–Addition is held to be not justified. [S. 69B, 148, 151]
S. 147 : Reassessment-After the expiry of four years-No new tangible material-AO seeking to correct error in original assessment – Held to be not permissible. [S. 148]
S. 143(3) : Assessment-Survey-Difference in stock-Statement recorded during survey not under oath-Retraction of statement with explanation-Addition is held to be not justified. [S. 133A]
S. 92C : Transfer pricing–Arm’s length price–Broad casting-Multi-system operator in distribution of television channels-Adjustment of 10 %-Ad hoc determination of Arm’s length price is unsustainable. [S. 40A (2)(b)]