S. 153B : Assessment-Time limit-Exchange information-Reference was on 14-11-2012-Article 26 ceased to exist after 30-8-2010-Period of limitation could not be extended under Explanation (ix) to section 153B to frame assessment based on such reference-Assessment order was quashed and set aside on ground of limitation-DTAA-India-Swiss [S. 90, 90A, 153B(ix) Art.24, 26]

S. 149: Reassessment-Time limit for notice-For assessment year 2015-16, notice under section 148 issued on 29-7-2022 was beyond the limitation period prescribed under section 149 and was barred by limitation.[S. 68, 148, 148A(b), 148A(d)]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Beyond three years-Income alleged escapement was less than 50 lakhs, i.e., 32.78 lakhs-Reassessment notice and consequential assessment orders were void ab initio, hence quashed. [S. 56 (2) (vii)(b), 147, 148, 148A(b), 148A(d), 149(1)(b)]

S. 147 : Reassessment-Cash credits-Accommodation entries-Share capital-Failure to comply with filing with ROC-Huge share capital in balance sheet-Reassessment proceedings were quashed and set aside.[S. 68, 148]

S. 147: Reassessment-Unexplained investment-Information from Insight portal-Objection was not disposed of-Reassessment order was quashed and set aside. [S.69, 148]

S 144: Best judgment assessment-Amounts of investments not fully disclosed in books of account-Purchase of flat-Investment from maturity of fixed deposits-Matter was restored to the file of the Assessing Officer for a fresh examination. [S.69B]

S. 90: Double taxation relief-Foreign tax credit-Filing of Form No. 67 is not mandatory, but it is a directory requirement, and mere delay in filing Form No. 67 as per provisions of Rule 128(9) will not preclude the assessee from claiming benefit of foreign tax credit in respect of tax paid outside India.-DTAA-India-USA.[R. 128, Form No 67, Art. 25]

S. 80P : Co-operative societies-Mutuality-Three classes of members, namely, regular members, associate members and nominal members-Mutuality cannot be denied-Interest from fixed deposit with co-operative Bank-Within mandatory limit allowed deduction-Rental income, commission and other income-Disallowance affirmed. [S. 40(a)(ia), 57, 80P(2)(a)(i), Karnataka Cooperative Societies Act, 1959,S. 18]

S. 80GGB: Contribution-Companies-Political parties-Remanded to the file of the Assessing Officer for verification. [Finance Act, 2017, Companies Act, 2013, S. 182]

S. 80G: Donation –Time limit-Delay in filing of Form No 10B-CIT (E) rejected application on the ground that it was beyond the time limit prescribed for filing of Form No. 10AB-Commencement of activity-Matter was to remanded to CIT (E) for reconsideration of application on merits.[Form No 10AC]