S. 153A : Assessment-Search-Pendrive-Investigation agency only obtained a certificate about details of pen drive and person in whose custody it was seized and except those details nothing was there in certificate-Certificate was not completely filled up by revenue authorities-Four conditions stipulated in section 65B(2) i.e., (a) to (d) along with section 65B(4) of Indian Evidence Act, 1872 were not followed while obtaining certificate-Certificate is not a valid certificate in eyes of law-Pendrive could not be considered as admissible evidence as per provisions of section 65B of Indian Evidence Act. [ S. 132, Indian Evidence, Act 1872, S. 65B(2), 65B(4)]

S. 153A : Assessment-Search-Limitation-Panchnama-No seizure of books of account or document-Panchnama was drawn only for removal of restraint order under section. 132(3)-Assessment order is barred by limitation. [S. 132, 132(3) 153B]

S. 148 : Reassessment-Notice-Transfer of case-Mandate of section 127 is not followed-Notice issued is without jurisdiction hence quashed.[ S. 92CA(2), 127, 144C(15), 144C(13), 147, 153(2)]

S. 147 : Reassessment-No sanction was recorded on the date of issuance of notice-Reassessment is not valid-Notice under section 143(2) is not issued-Reassessment is quashed.[ S. 143(2), 148, 149,151]

S. 147 : Reassessment-Search and seizure-Information from DDI (Inv)-CIT(A) has quashed the reassessment on the ground that the assessment should have been farmed under section. 153A/ 153C of the Act-Reassessment was not done on the basis of search-Order of CIT(A) is set aside with the direction to decide a afresh in accordance with law.[ S. 132, 148,153A, 153C]

S. 147 : Reassessment-No tangible material-Addition is made substantive basis in another entity-Reassessment is quashed.[ S. 148, 153A]

S. 147 : Reassessment-Business income-Value of any benefit or perquisite, arising from exercise of business or profession-Merger-Demerger-Transfer of Passive Infrastructure Assets (PIA) to ICTIL and subsequent amalgamation into Indus Towers, and demerger of telecom undertaking of ABTL-Scheme approved by High Court-No colourable device-Provision of section 28 (iv) cannot be applied-Non-compete fee-Change of opinion-amount debited in P&L Account as Employees Stock Scheme had been disallowed as being a contingent liability-Change of opinion-Reassessment is not valid.[ S.28(iv), 37(1), 1115JB,148]

S. 145 : Method of accounting-Unaccounted stock-Cash found during survey-Books of account was not complete-Justified in rejecting the books of account-Bogus purchases-Restricted the disallowance to 6% of bogus purchases as against 12.5% estimated by the CIT(A). [S. 133A, 145 (3)]

S. 144C : Reference to dispute resolution panel-Limitation-Order is barred by limitation.[ S.92CA (3A), 143(3) 153 (1), 153(4)]

S. 144C : Reference to dispute resolution panel-Limitation-Order is barred by limitation.[ S.92CA (3A), 143(3) 153]