S. 147: Reassessment-International transaction-Case transferred to transfer pricing officer-Verification of records-Held, reopening of assessment bad in law. [S. 143(3),148]

S. 147 : Reassessment-Change of opinion-Original assessment made on scrutiny-no tangible material coming into possession of AO for formation of belief that income had escaped assessment, Reassessment on materials is impermissible. [S. 143(3), 148]

S. 147: Reassessment-Change of opinion-Initiated basis perusal of case records itself is a clear case of change of opinion and is liable to be quashed. [S. 148]

S. 147 : Reassessment-Loose slip-Information received from Central Bureau of Investigation (CBI)-Affidavit-Assessment completed without verification of books of accounts as the same were impounded by CBI was in violation of natural justice-Matter remanded back to AO.[S. 148,ITATR.29]

S. 147 : Reassessment-No fresh material with-Opinion based on incorrect basis-Proceeding on the basis of conjectures-Reassessment is without jurisdiction. [S. 148]

S. 147 : Reassessment-Best Judgement assessment-No addition is made on the basis of recorded reason-Reassessment is bad in law-Levy of penalty is not valid .[S. 144, 148,271 (1)(c)]

S. 145 : Method of accounting-Assessee explaining methodology of accounting in respect of sales and value added tax-Commissioner (Appeals) allowing relief-Cognizance of section 145 read with section 145A(ii) and relevant income computation and disclosure standard IV for revenue recognition not taken into consideration-Matter remitted to Commissioner (Appeals) for adjudication afresh taking into consideration section 145 read with section 145A(ii) and Income Computation and Disclosure Standard IV-Commissioner (Appeals) on basis of documents presented before him granting relief to assessee without getting remand report from the A.O. by deleting additions and also granting deduction u/s. 80C-Matter restored to CIT(A) for adjudication of issue afresh after obtaining remand report from A.O. [S. 80C,145A(ii),R. 46A]

S. 145 : Method of accounting-Without show cause notice rejection of books oof account is bad in law-Books of accounts rejected u/s. 145(3) without issuing any Show Cause Notice and framing assessment u/s. 143(3) and not u/s. 144 indicates that assessment is bad in law-Purchases verified by AO and found to be genuine and purchases correctly recorded in books of accounts and stock register, books of accounts cannot be rejected-Cash sales and cash deposited in bank was held to be genuine and where assessee maintains proper books of accounts audited by Charaterd Acountant-Stock register, CIT(A) was not justified by estimating income by applying NP Rate and books of accounts were to be accepted. [S. 68 ,115BBE, 143(3) 144, 145(3)]

S. 145: Method of accounting-Accrual system of accounting-Interest income received during the relevant AY to be taxed in the said AY when assessee follows accrual system of accounting

S. 145 : Method of accounting-Non accounting of expired stock as part of opening stock-no evidence of sale of obsolete stock-notional estimation of profit for not showing the obsolete stock as part of opening stock unjustified. [S. 37]