S. 251 : Appeal-Commissioner (Appeals)-Powers-Delay of 1694 days-Appeal is dismissed-CIT(A) cannot dismiss the appeal for default expressly or by inevitable implication; appellate authority has to decide the appeal on merits-Matter remanded to the file of CIT(A) to decide on merits.[S. 250]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Setting aside of matter back to the AO-Failure to file return-Best judgement assessment-No power to set aside the matter w.e.f 1st June 2001-the matter is restored back to the CIT(A) with a direction to call for a remand report from the AO and then adjudicate the matter. [S. 139, 142(1), 144]

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Intimation-Rectification-No power to give direction or finding in respect of issues which are not subject before him. [S.143(1), 154, 249]

S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-Appeal filed before wrong forum-Delay of 657 days in filing an appeal-Form No 35 was filed before the AO instead of CIT(A)-Delay is condoned-Assessee is directed to deposit Rs. 5,000 to Prime Minister National Relief Fund within thirty days-CIT(A) is directed to decide the appeal on merits. [S. 249(3),250,253(3), 254(1)]

S. 153A: Assessment-Search-Dumb document-Quotations-Loose papers-Addition is deleted. [S.69C]

S. 153A: Assessment-Search-Information from Investigation wing-Foreign Bank-The assessee has accepted the relevant documents as genuine-Not necessary to follow the procedure laid down in S. 65B of Indian Evidence Act, 1872-Admissible as evidence-Deposits in HSBC London-Income from other sources-Art. 23(3) of Indo-UK DTAA is not automatically applicable-DTAA-India-UK-Bank account showed closed status-Notional interest income cannot be estimated. [S. 90, Indian Evidence Act, 1872, S.65B, Art. 23(3)]

S. 151 : Reassessment-Sanction for issue of notice-Notice was issued before the expiry of four years from the end of the relevant assessment year-It should have been issued after obtaining the satisfaction of Jt. CIT-The approval obtained from the Principal CIT is not valid. [S. 147, 148, 151(ii)]

S. 147: Reassessment-Incorrect information-Reassessment is not valid-Receipt on sale of goods-Addition is deleted. [S. 68, 148]

S. 147: Reassessment-Cash deposits-No addition was made in respect of reasons recorded-Issue which is not subject of recorded reason-Addition cannot be made-Additional ground is admitted.[S. 148, 254(1)]

S. 147 : Reassessment-Survey-Information from Investigation Wing-Re assessment is valid-Expenses through international credit cards-Addition is sustained.[S.69C, 133A, 148]