S. 139 : Return of income–Delay in filing revised return-Amalgamation-Sanction of company Law Tribunal is not binding on Income-Tax Authorities-Application for condonation of delay to me made. [S.119, Companies Act, 2013, S. 230(5), Constitution, Art. 226]

S. 133A : Power of survey–Undisclosed income-Admission of excess stock and excess cash–Addition is held to be valid–Mentioning of wrong section in the assessment order does not make addition as unsustainable. [S. 69B, 69C, 131]

S. 132A : Powers-Requisition of books of account–Search and seizure–Cash found from the employees of Courier services-Explanation that the cash was withdrawn from several bank accounts–Failure to produce relevant documents–Issue of warrant of authorisation is held to be valid. [S. 131, 132, Art. 226]

S. 132(4) : Search and seizure-Statement on oath–Evidentiary value–Retraction-Statement cannot be discarded merely on ground that it was retracted. [S. 131, 132, 133A]

S. 127 : Power to transfer cases–Transfer for purposes of co-ordinated investigation-Mode of investigation need not be disclosed-Notice to transfer implies that both the Commissioners are in agreement–Manner of agreement need not be recorded-Transfer is held to be valid–Writ is held to be not maintainable. [S. 127(2)(A), Art. 226]

S. 115JA : Book profit–Deduction u/s. 80HHC is to be allowed on the basis of book profits and not on the basis of eligible profits under S. 80HHC. [S. 80HHC]

S. 80IB(10) : Housing projects-One of the unit constructed exceeded the upper limit-Deduction cannot be denied to entire housing projects – Exemption is not allowable only in respect of the unit exceeded the prescribed limits.

S. 80HHC : Export business–Supporting manufacturer-Supporting manufacturer is at par with actual direct exporter of goods when it comes to deductions that are available-Remanded the matter back to Tribunal for fresh adjudication. [S. 28(iiid)]

S. 69C : Unexplained expenditure-Income from undisclosed sources-Bogus purchases–Bhanvarlal Jain group-Hawala concern-Addition cannot be made of entire purchases based on the report of Investigation wing–When sales are accepted purchases cannot be rejected-Estimate of profit of 3% of bogus purchases–Held to be justified–Appeal of revenue is dismissed-No question of law. [S. 260A]

S. 69A : Income from undisclosed sources-Cold storage-No purchase and sale of products-Deletion of addition is held to be justified.– Cash in hand in books of account was found to be more than actual cash found during search- No addition can be made as cash credits [S.68, 132, 153A, U.P. Regulation of Cold Storage Act, 1976]