S. 147 : Reassessment-After expiry of four years-Change of opinion –Interest on capital work in progress-Reopening based on material already on record-No failure by assessee to disclose fully and truly all material facts-Notice quashed. [S. 36(1)(iii), 143(3), 148, Art. 226]

S. 147: Reassessment-After expiry of four years-Change of opinion-Reopening an assessment to disallow interest expense, where a query on the underlying loan and its utilisation was raised and answered during the original scrutiny assessment, amounts to a mere change of opinion and is not justified. [S. 24, 57, 143(3), Art. 226]

S. 147 : Reassessment-After expiry of four years-Change of opinion-Where assessee had fully and truly disclosed all material facts for claim of interest expense, reopening of assessment on ground that said interest ought to have been capitalised to work-in-progress amounts to a mere change of opinion and is invalid. [S. 36(1)(iii),. 148, Art. 226]

S. 147 : Reassessment-After expiry of four years-Change of opinion-HUF as a partner-All facts disclosed during original assessment under section 143(3)-Reopening invalid. [S. 143(3), 148, 184, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Reopening on the ground that deduction under section 80HHC ought to have been determined after setting off brought-forward losses held to be a mere change of opinion on the same material and, hence, not permissible. [S. 80HHC, 143(3), 148, Art. 226]

S. 28(i) : Business loss-Mark‑to‑market loss on forward contracts-Ascertained liability-Allowable as business loss-Not speculative-Not required to be added back while computing book profits under section 115JB. [S. 43(5), 73]

S. 28(i) : Business income-Adventure in the nature of trade-Surplus on sale of premises-Where assessee-company, dealing in real estate, sold office premises before taking possession, surplus was assessable as business income as cumulative facts established intention was to resell for profit, not for own use. [S. 45, 260A]

S. 14A : Disallowance of expenditure-Exempt income-Shares held as stock‑in‑trade excluded from Rule 8D; no disallowance where assessee’s own funds exceed tax‑free investments. [R. 8D]

Prohibition of Benami Property Transactions Act, 1988.

S.5: Property held benami liable to confiscation-Benami transactions-Change of law-Order of Tribunal following Supreme Court decision holding amendments brought in 2016 not retrospective-Appeal against order passed by Tribunal Department given liberty to proceed based on outcome of review petition filed before Supreme Court. [S. 2(9), 3,4, Art. 226]

Electricity Act, 2003,

S. 3: Writ-Maintainability-State instrumentality-Tariff determination-Renewable energy-Wind power-Accelerated depreciation-The Nigam could not take advantage of its dominant position to bind them to an inapplicable tariff for the entire project life-The plea of estoppel based on execution of power purchase agreements was rejected-Orders of the Electricity Commission and the Appellate Tribunal were upheld.-Order No. 1 of 2010 dated 30-1-2010. [S, 61(h), 62(1)(a), 86(1)(e) Income-tax Act, 1961, S. 32, Art.12, 226]