S.147: Reassessment-After the expiry of four years- Export oriented undertaking —Mentioning of wrong year of commencement of manufacture in Form 56G, when other materials furnished indicated correct year of commencement of manufacture is not a case of failure to disclose material facts — The proviso to S. 147 cannot be invoked on the Assessing Officer’s omission or mistake- Reassessment notice is held to be not valid – Notice is not barred by limitation .[ S.10B,148 ]

S.147: Reassessment-After the expiry of four years- No failure to disclose material facts-Deduction was allowed after scrutiny -Reassessment is held to be bad in law – Revision application of of the assessee was allowed .[ S.10B, 143(3),148, 264 ]

S.132:Search and seizure – Survey converted in to Search- Seizure of unaccounted cash – Assessment pending- Writ to refund the amount of cash seized with interest was dismissed- On same set of facts second writ petition is not maintainable on the principle of Res Judicata. [ 132A, 1331, 153A, art. 226 ]

S. 80I : Industrial undertakings – Two units- No separate books of account- Division of income between the two units in proportion of their internal publication and circulation of the Ahmedabad edition is held to be proper .

S. 80G : Donation -Spending more than 5 percent of income on pooja and telecast – Denial of approval was not justified when the exemption was granted under S.12AA of the Income -tax Act .[ S.12AA, 80G(5)(vi) ]

S. 69A : : Unexplained money – Income from undisclosed sources — Illegal gains by short supply of contracted articles – Addition as income from undisclosed source is held to be justified .

S.68:Cash credits — Share capital- The assessee being a private limited company the burden of proof was on a higher pedestal even though the assessee had furnished the particulars of the bank accounts, passport, permanent account number card, addresses and earnings by the shareholder-cum-director and the money had been invested through banking channels- the share subscribers did not have their own profit making apparatus and were not involved in business activity- Money was routed through – Profit motive normal in the case of investment was entirely absent -No profit or dividend was declared -Genuineness of transactions were doubted –Addition was held to be justified -No question of law arose . [ S.260A ]

S. 40A(3) :Expenses or payments not deductible – Cash payments exceeding prescribed limits -Deletion of addition by Tribunal on ground that expenditure negligible considering turnover of assessee -Matter Remitted to AO to redo assessment on consideration of related documents .

S. 40(a)(ia): Amounts not deductible – Deduction at source – Fees for professional or technical services – third party administrator for insurance companies – Payment through assessee- Not liable to deduct tax at source- No disallowances can be made [ S. 194J, 260A ]

S. 40(a)(ia): Amounts not deductible – Deduction at source – Fees for professional or technical services – third party administrator for insurance companies – Payment through assessee- Not liable to deduct tax at source- No disallowances can be made [ S. 194J, 260A ]