S. 153C : Assessment-Income of any other person-Search-Addition in the hands of third person based on information obtained during search and seizure proceedings-Primary onus on revenue to prove falsehood of the assessees submissions-No addition can be made merely on basis of suspicion-cogent material required to make addition. [S. 132(4)]

S. 147 : Reassessment-Specific Information-Reassessment was held to be valid-Addition of salary is held to be not justified. [S. 69A, 148]

S. 147 : Reassessment-Deemed dividend-Without bringing any fresh material on record, on fresh application of mind-Reassessment is bad in law-On merit also addition as deemed dividend was deleted. [S. 2 (22)(e)]

S. 147 : Reassessment-Change of jurisdiction of Assessing Officer-Reassessment order passed by the ITO after the transfer under section 127 to Dy.CIT-Order quashed-Reassessment order originally framed by ITO was without jurisdiction. [S. 127, 129, 148, 153A, 263]

S. 147 : Reassessment-After the expiry of four years-no allegation about non-disclosure of full and true particulars in original assessment-Reopening is bad in law. [S. 148]

S. 145 : Method of accounting-Ad hoc method of accounting-Followed by AO and assessee-Held unacceptable-Remand-Fresh consequential grounds-Permissible-Matter remanded to the Assessing Officer.

S. 144C : Reference to dispute resolution panel-Transfer Pricing-Adjustment on account of Notional Income in respect of interest on delayed receivables was directed to be deleted on verifying the same with the credit period in master service agreement, and also verifying whether the same is subsumed in the working capital adjustments.

S. 143(3) : Assessment-Jurisdiction of Assessing Officer-Order giving effect to the order of the Commissioner-After passing of reassessment proceedings case was transferred to another Assessing Officer-Order giving effect by the original Assessing Officer after transfer of jurisdiction is held to be bad in law. [S. 124, 127 143(3), 147, 148, 263]

S. 143(2) : Assessment-Mandatory issue of notice-Jurisdiction-Transfer from Shillong to Guwahati-Order passed by Assessing Officer, Guwahati without issuing notice under section 143(2) and only in pursuance with notice issued by ITO, Shillong who did not enjoy jurisdiction over assessee was null and void. [S. 120, 143 (3)]

S. 132(4) : Search and seizure-Introduction of undisclosed income as share capital of company-statement of assessee-transactions made by him in FY 2009-2010 and including amount in return for AY 2010-11. AO accepting admission but bringing sum to tax in 2009-10. Sum could not be taxed in AY 2009-10. [S. 68, 132, 153A]