S. 158BD : Block assessment – Undisclosed income of any other person -Recording of satisfaction can be done even after assessment of person searched , however must be recorded with in reasonable time. Recording of satisfaction was done after nine months after assessment of person searched is held to be bad in law. [ S.158BC ]

S.147: Reassessment — Change of opinion-Un explained investment -Reasons not recorded -Reassessment on the basis of report of departmental Valuer is held to be bad in law . [ S.148 ]

S.147: Reassessment —Reopening of assessment based on assessment of subsequent assessment Year without any new material is found ,reassessment was not valid. [ S. 80IA, 148 ]

S. 80IC : Special category States -Interest earned on fixed deposit maintained with bank for obtaining bank guarantee is not derived from business hence not entitle to deduction . [ S.2(13),80HH, 263 ]

S. 69C: Unexplained expenditure – Bogus purchases-100% disallowance is confirmed-The right of cross-examination is not absolute. No prejudice is caused to the assessee by non granting of cross examination if the assessee has not discharged the primary onus. The fact that purchase bills are produced and payment is made through banking channels is not sufficient if the other evidence is lacking.

S. 68:Cash credits- Share capital- Mere submission of name & address, Balance Sheet & bank statement of the subscribers is not sufficient to discharge the onus. The assessee has to justify the allotment of shares to outsiders at exorbitant premium with cogent material and not bald statements. Addition is held to be justified. [S.56(2)(viib) , 2(24)(xvi) ]

S.40(a)(ia):Amounts not deductible – Deduction at source- Recipient has filed belated return hence conditions not satisfied – Liable to deduct tax at source-Liable to pay tax with interest [ S.201(1)]

S. 10 (23C): Educational institution- Merely because surplus profit earned in educational activities did not automatically presuppose a business activity that invalidated the exemption as long as surplus was utilised for charitable purposes . [ S.2(15), 10(23C)(via),11(4A) ]

S.2(22)(e ): Deemed dividend- Loan to shareholder — Finding that loan was not trading transaction therefore assessable as deemed dividend .

S. 92C : Transfer pricing – Arm’s length price –It would be impossible to find comparable with all similarities including the similarity of turnover- A functionally similar company cannot be excluded as comparable only on ground that company had a higher turnover .