S. 147 : Reassessment – Search and seizure — Information received from investigation wing —Not independently verified from record —Correct course of action would have been to proceed under section. 153C and not under section 147 – Reassessment was quashed [ S. 132, 148 ,153C ]

S.147: Reassessment —High premium with share application money – No tangible material — Mere information that assessee had received a high premium, cannot be said to be a reason to form belief that income of assessee had escaped assessment- Reassessment notice is held to be bad in law [S. 68 , 143(1) ]

S.147: Reassessment —Housing project – Information in subsequent year – Not competition of the project – Assessing Officer need not conclusively prove income chargeable to tax escaped assessment at stage of notice — Reassessment notice is held to be valid- If flat purchaser de facto in exclusive possession of dry Balcony attached with flat, area of dry balcony includible while computing Built-up area of flat- Building Completion Certificate and the Occupation Certificate .not issued by the local authority – Not entitle to deduction u/s 80IB (10 of the Act [ S.80IB(10) ,148 ]

S.147: Reassessment — Capital gains — Agricultural Land- Change of user by Panchayat or land revenue authorities -Not showing positive income – Reassessment notice is held to be not valid [ S.2(14)(iii),10(37) ,133A, 148 ]

S.147: Reassessment — Under invoicing of export invoices -Reassessment notice entirely based on the M. B. Shah Commission report without application of mind – Held to be not valid-Period during which lockdown was in force in country due to COVID 19 pandemic was to be excluded for purpose of computing time set out for pronouncement of judgment by Tribunal i.e. within 90 days from date of hearing . [ S.148, 255 , ITAT R. 34(5) ]

S.147: Reassessment-After the expiry of four years- Freezer security deposits —Lapsed liability taxed in original assessment on proportionate basis over four years from date of receipt —Tribunal finding in earlier year that amount taxable only in year of termination — Reassessment not valid.[ S.148 ]

S.145: Method of accounting – Estimation of commission income at a higher rate merely on basis of presumption that assessee had shown a very small margin without any convincing evidence is not sustainable- Mismatch in figures between balance-sheet of assessee and balance-sheet of other parties — Difference cannot be assumed unexplained income . [ S. 68, 145(3) ]

S.143(3): Assessment — Conversion of limited scrutiny into complete scrutiny -Principal Commissioner according approval in a mechanised manner — CBDT instructions- Violation of instruction No. 5 Of 2016 dt 14-7-2016 [2016 385 ITR (St.) 56 . [ S.142(1) , 144A, 292BB]

S.115JB: Book Profit- Sick Industrial Company —Discharged by Board for Industrial and Financial Reconstruction – Net worth turning positive – Matter remanded to the file of Commissioner (Appeals) to decide on merit by passing speaking order. [Sick Industrial Companies [S. 40(a) )(ia), Special Provisions) Act, 1985, S. 17(1) ]

S.92C: : Transfer pricing – Arm’s length price – Royalty -Paid for basket of services — Adjustment is held to be not justified -Advertising, marketing and promotion of sales expenses —No proof of existence of International Transaction —Adjustment made in respect of advertising marketing and promotion of sales expenses to be deleted -Expenses reimbursed matter remanded [ S.92CA ]