S. 148 : Reassessment–Notice–Notice against dead person-Merely because in response to notice issued against Jayantilal Harilal Patel petitioner had informed Assessing Officer about death of assessee and asked him to drop proceedings- it could not, by any stretch of imagination, be construed as petitioner having participated in proceedings and, therefore, provisions of section 292B would not be attracted –Notice is held to be invalid. [S. 2(7) / 2(29), 159, 147 292B]

S. 147 : Reassessment–Two set of reasons–Gist of reasons same–Sanction was obtained–Mere fact that tax authorities conveyed reason twice would not be fatal -Reassessment is held to be valid. [S.143(1), 148]

S. 147 : Reassessment–Notice–Non disposal of objection by observing that it was not feasible to pass separate speaking order in respect of objections raised-It is mandatory to decide objections one way or other-Not curable defects-Non-adjudication of objections after receiving same, would render consequential actions and orders illegal. [S. 144, 148]

S. 147 : Reassessment-Cash credits–Gift from non relative-Suspicion – Reassessment is held to be not valid. [S.68, 143(1), 148]

S. 147 : Reassessment-After the expiry of four years- Acceptance of loans and deposits-Otherwise than by account payee cheque or account payee bank draft–reassessment proceedings was merely based on change of opinion of Assessing Officer, impugned order passed by Tribunal up held. [S. 148, 269SS]

S. 115JB : Book profit-While computing book profit, provision made for payment of wealth tax could not be included in it as section 115JB only refers to income-tax paid or payable or provisions made therefor –No question of law. [S. 260A]

S. 69A : Unexplained money–Unexplained cash receipts-Description of property was not furnished–Addition is held to be justified.

S. 57 : Income from other sources–Interest–Intercorporate deposits (ICDS)-Interest received is held to be taxable as income from other sources–Interest paid to sister concern is held to be allowable as deduction. [S. 56]

S. 54F : Capital gains–Capital asset-Investment in a residential house–Booked a flat in January 1981–Right in the flat was sold in the year 2005 -Allowable deduction. [S. 2(14), 45]

S. 41(1) : Profits chargeable to tax-Remission or cessation of trading liability–Not claimed any deduction of any trading liability in any earlier year-Addition cannot be made.