S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Incriminating material referred in satisfaction note not connected to assessee-Order is held to be invalid and quashed.
S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Incriminating material referred in satisfaction note not connected to assessee-Order is held to be invalid and quashed.
S. 153A : Assessment-Search-No incriminating material found in search-Alleged bogus long-term capital gains-Amalgamation approved by High Court-No evidence to prove transactions were bogus-Addition is deleted-No search on assessee-No assessment order could have been passed. [S. 10(38) 132, 133A]
S. 147 : Reassessment-Cash credits-Undisclosed income-Source of cash deposits explained-Addition not sustainable-Reassessment invalid.[S. 68, 148]
S.147: Reassessment-After the expiry of four years-With in four years-Raised specific query in the original assessment proceedings-No new tangible material-Reassessment is bad in law.[S. 143(3 148]
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment is quashed. [S. 148]
S. 144C : Reference to dispute resolution panel-Limitation-Legal issue-Can be raised at any time-Matter remanded to Assessing Officer to consider additional ground of limitation on Dispute Resolution Panel’s Direction. [S. 92CA, 153, 254(1), ITATR.11]
S. 144 : Best judgment assessment-Rejection of books of account-Estimate of gross profit-No purchases from shell companies-Declared greater profit from earlier years-No addition is warranted.
S. 153A : Assessment-Search-Information in Annual Information return is not incriminating material-Addition is deleted.[S. 5, 50C, 132]
S. 148 : Reassessment-Notice-Amalgamation-Factum of amalgamation intimated to Assessing Officer with request to cancel Permanent Account Number of amalgamating company-Notice in name of non-existent entity-Not sustainable.[S. 147]
S. 147 : Reassessment-Reasons recorded-Factual misstatements and inaccuracies-Sanction of commissioner without proper application of mind-Dispute Resolution Panel-Admitting errors-Reassessment is bad in law.[S.144C, 148, 151]