S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Specified Authority-Sanction by Principal Commissioner of Income Tax-Reassessment notice and order is bad in law.[S.148, 148A(b), 148A(d), 151(ii)]
S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Specified Authority-Sanction by Principal Commissioner of Income Tax-Reassessment notice and order is bad in law.[S.148, 148A(b), 148A(d), 151(ii)]
S. 148 : Reassessment-Notice-Additional ground-Legal issue-Time for issue notice under Section 143(2) against original return had not lapsed-Reassessment notice is bad in law-Limitation-Time-limit to be reckoned from date of return whether filed under Section 139(1) or 139(5) or in response to notice under section 142(1). [S. 139(1),139(2),139(5), 142(1), 143(2) 147]
S. 147 : Reassessment-Substantial difference in consideration shown on registered sale deed and sale agreement-Reassessment is valid-Cash credit-Unexplained investment-Source is established-Addition is deleted.[S. 68,69, 148]
S. 147 : Reassessment-With in four years-No specific query was raised in the course of original assessment on which the reassessment is initiated-Reassessment is valid-Electrical installations-Entitle to depreciation at 15%-On merits additions are set aside to the file of Assessing Officer. [S. 2(47), 14A, 32, 40(a)(i), 148]
S. 147 : Reassessment-No addition is made on the basis of recorded reasons-Reassessment is bad in law-The AO lacks jurisdiction to make independent addition-Limited scrutiny-Not obtaining approval for converting limited scrutiny in to complete scrutiny-Order is not valid. [S. 2(22)(e), 143(3), 148]
S.147: Reassessment-After the expiry of four years-Cash credits-Accommodation entries-Objection is not disposed-Information from ADGIT Investigation (OSD)-The addition made without enquiry and without application of mind-Reassessment is quashed. [S.143(1) 148]
S. 145 : Method of accounting-Books of account-Rejection of estimation of profits-Rejection of books of account is held to be not justified. [S. 44AB, 145(3)]
S. 144C : Reference to dispute resolution panel-Not an eligible assessee-Assessment-Limitation-Assessment order is bad in law-Additional ground is allowed.[S.92CA(3A), 144C(15)(b), 153 (4) 254(1)]
S. 132: Search and seizure-undisclosed income-bogus purchases-failure to rebut statement of the broker by documentary evidence by the Assessee, restricting addition to 12.5 percent is held to be proper [S. 132]
S. 115BBE-Tax on specified income-Determination of tax in certain cases-Unaccounted stock declared during survey-Excess stock being part of total business stock-Cannot be assessed as deemed income [S.69, 69B]