S. 153C: Assessment-Income of any other person-Search-Recording of satisfaction-The AO has recorded the satisfaction not as per the statutory convention-The entire assessment is vitiated and bad in law-Addition made on presumption was deleted. [S. 132]
S. 153C : Assessment-Income of any other person-Search-Seized documents-Subsequent exchange agreement-Addition was deleted. [S. 68, 69]
S. 153C: Assessment-Income of any other person-Search-Satisfaction note-Required to be recorded for each assessment year-Consolidated satisfaction note recorded for different assessment years-Bad in law-Approval-Mechanical manner-Order quashed. [S. 153D]
S. 153C: Assessment-Income of any other person-Search-Undisclosed income-Noting loose sheet-Seized from third party-Addition was deleted. [S. 132(4) 292C, Indian Evidence Act, S. 114]
S. 153A: Assessment-Search-Undisclosed income-Manufacturing facility of the assessee does not make it feasible for packaging of the products in small packets-First appellate authority has rightly appreciated the veracity of the evidence furnished by the assessee after verification-Input-output ratio-Order of CIT(A) was affirmed.[S. 132]
S. 153A: Assessment-Search-Undisclosed income-The assessee received software services, and the consideration paid for such services cannot be disallowed. [S. 37]
S. 147: Reassessment-Search-Incriminating documents-Notice issued on the basis of documents seized from a third party not pertaining to the assessee-Reassessment was quashed. [S. 69, 148, 153C]
S. 144C: Reference to dispute resolution panel-Direction of DRP-Final assessment order not in conformity with the directions of DRP-The assessment order is quashed-Non-service of order is not invalid.[S.80IA, 144C (13)]
S. 143(3): Assessment-Non-existing entity-Intimated the AO of the merger-Prior to the insertion of S. 170A w.e.f. 1st April, 2022, there was no provision enabling the filing of a modified return-The order passed by the AO is void ab initio. [S.170A]
S.143(3): Assessment-Limitation-Generation of multiple DINs by AO-Not barred by limitation.[S.153]