S. 147 : Reassessment-Reason for reopening assessment did not survive-No addition can be made on other issues. [S. 45, 148]
S. 147 : Reassessment-Reason for reopening assessment did not survive-No addition can be made on other issues. [S. 45, 148]
S. 147 : Reassessment-Order passed without disposing objections-Entire assessment proceedings vitiated. [S. 143(3), 148]
S. 147 : Reassessment-Cash deposited and property purchased-Notice of reassessment was held to be valid-Matter remanded to examine the cash deposited, after giving an opportunity of being heard. [S. 143(1), 147, R. 46A]
S. 147 : Reassessment-Information from Investigation wing-Notice on the basis of incorrect and non-existing reason-Non application of mind-Reassessment is not valid. [S. 68, 131, 147(b), 148]
S. 147 : Reassessment-After the expiry of four years-No allegation in the reasons recorded of any omission or failure on the part of the assessee in disclosing fully and truly all material facts necessary of assessment-Notice is void-ab-initio. [S. 148]
S. 145 : Method of accounting-Completed contract method-Accepted in earlier years-Method cannot be substituted by the percentage competition method
S. 144 : Best judgment assessment-Estimation of gross profit-Sluggish economic conditions-CIT(A) accepting the gross profit declared by the assessee-No business could have a minimum threshold gross profit every year just to satisfy the whims of the Assessing Officer-Held to be proper. [S. 145(3)]
S. 143(3) : Assessment-Income from undisclosed sources-Cash and cheque deposits in bank accounts-Transactions carried out on behalf of others-Entire deposit cannot be assessed as income from undisclosed sources-Profit element is estimated at 20 per. Cent. [S. 133A]
S. 143(3) : Assessment-Trader in Iron and steel-Sales not doubted-Profit element is estimated at 5 % of such purchases.
S. 143(3) : Assessment-Income from undisclosed source-Firm-Deposit of money in partner’s capital account-Explained the source-Addition cannot be made as undisclosed income of the firm-Cash deposited in the bank account of concern was accepted as genuine-Assessee received the payment by banking channels-Addition cannot be made as undisclosed income of the firm. [S. 69]