S. 147 : Reassessment-After the expiry of four years-Borrowed satisfaction-Contrary to facts-All information was available while passing the original assessment order-Approval without application of mind-Reassessment is bad in law. [S. 132, 133A, 148, 151, 153A, 153C]

S. 147 : Reassessment-After the expiry of four years-Borrowed satisfaction-Reassessment is not valid-Approval is not valid [S. 132, 133A,148, 151, 153A, 153C]

S. 144C : Reference to dispute resolution panel-Assessment-Limitation-Draft assessment order-Objections a day late-And Dispute Resolution Panel dismissing objections as filed late-Assessing Officer is bound to complete assessment within a month from last date for filing objections-Order passed beyond that date ultra vires.[S.143(3)]

S. 143(3) : Assessment-Amalgamation-Intimation to Department with the copy of order approving merger-Order passed in name of non-existent entity void and set aside.

S. 143(3) : Assessment-Entries in the books of account-Sale of land-Entries in books is not conclusive-Right income should be taxed in right hands, under right head of income in right year of assessment-Addition as undisclosed income is deleted. [S. 4, 69, 133(6), 145]

S. 143(3) : Assessment-Unaccounted expenditure and receipts-Only profit element in unaccounted business receipts and net result of unaccounted receipts and expenditure could be brought to tax-Assessment made substantively in hands of company-Protective addition in hands of director is deleted-Certificate from Gram Panchayat secondary evidence-Primary Evidence of crops, income and expenses unavailable-Fifty Per Cent. treated as agricultural income-Balance treated as income from other sources-Cash available in hands of group-Set off to be permitted-If sufficient cash available after set off and adjustments-No addition is permissible-Depreciation-Value of addition to block-Addition of differential depreciation is deleted. [S. 5, 10(1), 32 56, 69]

S. 143(3) : Assessment-Search-Income from undisclosed sources-Jewellery discovered in search-Assessing Officer cannot make separate addition over and above excess identified in search-Rate of tax-Penalties-Levy of tax under section 115BBE not in accordance with law. [S. 5, 69, 115BBE, 132, 132(4), 271AABB, 271AAC]

S. 143(3) : Assessment-Powers-Tribunal remanding matter to Assessing Officer to consider whether certain receipts constitute fees for technical services-Assessing Officer treating receipts as royalty-Beyond scope of remand-Reimbursement of expenses for use of software-Not fees for technical service-DTAA-India-USA [S. S. 9(1)(vi), 9(1)(vii), art. 13(4)]

S. 143(1) : Assessment-Intimation-Employees contribution to Provident fund and Employees’ State Insurance-Matter restored to Assessing Officer for verification-If Employees contribution had been remitted within due date from end of month in which salary disbursed entitled to relief. [S.143(1)(iv)]

S. 139 : Return of income-Foreign tax credit-Assessment-Benefit of tax paid in Kazakhstan is directed to be allowed.[S.139(4) 143993) Rule, 128(9), Form No 67]