S. 154 : Rectification of mistake-Mistake apparent from the record-Co-Operative Society-Deduction-Interest-Mutuality-Claims and contentions both on legal and factual-Matter remanded to Commissioner (Appeals)-Delay in filing of appeal is condoned.[S.80P, 143(1), 253(2)]

S. 154 : Rectification of mistake-Mistake apparent from the record-Interest on refund-Assessing Officer is directed to allow interest under Section 244A up to respective dates of credit of refund in account. [S. 244A]

S. 153C : Assessment-Income of any other person-Search- Limitation-From date of handing over of books of account and other documents by Assessing Officer of person searched to Assessing Officer of third person-Limitation will start on date of recording of satisfaction note by Assessing Officer of person searched that incriminating material referred to third person-Assessing Officer of person searched also having jurisdiction over third person-Assessment year falling beyond stipulated six assessment years and four relevant assessment Years-Barred by limitation. [S. 132, 153A(1)]

S. 153A: Assessment-Search-Income from undisclosed sources-Hotel business-Cost of construction of hotel building-Valuation referred to Departmental Valuation Officer-Difference in value cannot be added as undisclosed income-Rejection of books of account-Addition is not justified-Business loss-Carry forward-Allowed current year business loss and carry forward thereof for set off in subsequent years.[S. 69, 145 (3)]

S. 153A: Assessment-Search-Assessment completed-Prior to date of search-No incriminating material-Addition is bad in law-Fresh claim cannot be entertained-Assessments for years for which assessments abate-Assessee can lodge new claim not made in regular return of income-Statement-Retraction-Merely on the basis of statement addition cannot be made, if assessee shows he was wrong on facts he admitted. [S. 139,143(3)]

S. 151 : Reassessment-Sanction for issue of notice-Joint Commissioner had merely written “Yes, I am satisfied” and not that “It is a fit case for issue of notice under Section 148”-Approval mechanical and not valid. [S. 148, 151(2)]

S. 147 : Reassessment-Moratorium in force-Liquidation-Insolvency and Bankruptcy laws-Code has overriding effect over provisions of Act-CIT(A) is wrong in not adjudicating matter on merits-Matter restored to Commissioner (Appeals) for disposal on merits after affording assessee opportunity of hearing through Liquidator. [S. 147, 148, 178(6), (Insolvency and Bankruptcy Code, 2016,S. 14, 33(5), 53, 238]

S. 147 : Reassessment-Survey-Formation of belief of income escaped assessment on wrong facts-Non application of mind-Reason stated non filer-Record shows return was filed on due date-Reassessment notice and consequential order is held to be invalid.[S. 133A, 148]

S.147: Reassessment-After the expiry of four years-Additional ground-No failure to disclose material facts-Deemed dividend-Current transactions-Accumulated profits-Closing credit balance to be verified-Reassessment is bad in law. [S. 2(22)(e), ITAT R. 27]

S. 145 : Method of accounting-Change of method-Advance tax-Interest-Matter remanded. [S. 234A]