S. 153C : Assessment-Income of any other person-Search-Not mention of Document Identification No (DIN) in the assessment order-Subsequent separate communication of DIN is a superfluous exercise-Order invalid hence quashed-Circular No. 19 of 2019, dt. 14th Aug., 2019. [S.119, 292B ]
S. 153C : Assessment-Income of any other person-Search-Cash found in the premises-Cash kept for safe custody-No evidence produced to substantiate the claim-Addition is affirmed.
S. 153A: Assessment-Search-No incriminating documents-Loose sheet-Not estimate actual expenditure-Addition is not valid-Protective addition-Addition is confirmed in the assessment of director-No protective addition can be made in the assessment of the Company.
S. 153A: Assessment-Search-Admitted as undisclosed income-Not retracted-Order of CIT(A) deleting the addition is set aside. [S. 68]
S. 151 : Reassessment-Sanction for issue of notice-No approval is obtained before issue of reassessment notice-Re assessment is quashed as void ab-initio. [S. 147, 148]
S. 147: Reassessment-Within four years-Change of opinion-No new tangible material-Performance guarantee-Deposit-Addition was deleted on merits by CIT(A)-Additional legal ground on reassessment is admitted-Reassessment is quashed on the ground of change of opinion. [S. 37, 69, 148, 254(1), ITAT R 1963.R. 27]
S. 147: Reassessment-Change of jurisdiction-Notice is issued by the Assessing Officer who had jurisdiction-Later case was decentralized-No objection was raised before the Assessing Officer-Ground of jurisdiction is rejected [S. 120, 124, 127 148, 149, 151, 282, 282A, General Clauses Act, 1897, S. 27]
S.147: Reassessment-After the expiry of four years-Audit objection-Re assessment is valid.[S. 148]
S. 143(3): Assessment-limited scrutiny through CASS-Cash credits-The Assessing Officer cannot make addition other than the issue covered under limited scrutiny-CBDT Instruction No. 5 of 2016, dt. 14th July, 2016 [S. 143(2)]
S. 143(3): Assessment-Search-Abatement of assessment-Documents relating to company and directors are seized-Pending assessment is abated-Assessment has to be made under section 153A or 153C-Assessment order is quashed and set a side. [S.68, 132, 153A 153C ]