S. 151 : Reassessment-Sanction for issue of notice-Satisfaction recorded in a mechanical manner without application of mind-Additional ground Reopening held to be invalid. [S.147, 148, 254 (1)]

S. 148 : Reassessment-Notice-Reasons for reopening not supplied-Directed to supply reasons for reopening and only after disposal of objections, if any, raised, AO would proceed to re compute income of assessee in accordance with law-Matter remanded. [S. 69B, 147]

S. 147 : Reassessment-Change of opinion-Exemption-Notice was quashed on account of change of opinion and first proviso too section 147. [S. 10(26BBB), 148]

S. 147 : Re-assessment-Search-On money-Additional ground-AO made reopening relying upon information received from search proceedings in case of third party-Held reassessment proceedings null and void-Only 153C valid in case of information received from third party-Assessment was quashed. [S.132, 148, 153A, 153C, 254(1)]

S. 147 : Reassessment-Recorded reasons-Complete text of reasons recorded was not given-Sanction was vague-No new tangible material on record-Reassessment was quashed. [S. 148, 151]

S. 147 : Reassessment-Borrowed satisfaction-Cash credits-Accommodation entries-AO issued reopening notice merely on basis of information received from department and he had not pointed out as to how investment in question was unexplained income of assessee, order passed by AO was to be quashed. [S. 68, 132, 147, 148]

S. 143(3) : Assessment-Search and Seizure-On money-Loose sheets-Purchase of land Addition on the basis of statement of third party-AO made addition based on the statement given by third party-No incriminating material found suggesting the payment of on-money consideration-Tribunal Deleted addition. [S. 132(4), 132(4A)]

S. 142A : Estimate of value of assets by Valuation Officer-Search and seizure-DDIT (Inv)/ADIT (Inv) was empowered to make reference to Valuation Officer inserted by section 132(9D) only after 1-4-2017 by an amendment by Finance Act, 2017-Addition made on the basis of valuation report was held to be not valid-Valuation report cannot be considered as incriminating document. [S. 132(9D), 153A]

S. 132(4) : Search and seizure-Statement on oath-When the addition was made on account of seized material once again addition cannot be made on the basis of statement which will lead to double addition. [S. 132, 143(3), 153A]

S. 124 : Jurisdiction of Assessing Officer-Return filed in Kolkata-Proof of change of address in PAN database proved that assessee had changed his address properly and department was already in knowledge of address of assessee at Kolkata-Assessment initiated by Assessing Officer from Kanpur-Notice and assessment is held to be in valid. [S. 142(3), 143(3), 150]