S. 263 : Commissioner-Revision of orders prejudicial to revenue-Allotment letter prior to AY. 2014-15-Registration was on 9th December, 2014-Provision of section 56(2)(vii)(b)(ii) is not applicable-Revision is held to be not valid. [S. 56(2)(vii)(b)(ii)]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revision order passed on the basis of recommendation of Assessing Officer has no statutory sanction-Order is bad in law. [S. 143(3)]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Reference to dispute resolution panel-Order passed without complying the mandatory procedure prescribed u/s.144C is non-est-Order which is a nullity and non-est cannot be a revised. [S. 144C, Art. 14, 21]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Investment in new pant or machinery-Possible view-When an amendment is made to clarify or remove the hardship, the same is to be treated as clarificatory and it should be applied with retrospective effect-Revision is held to be not valid. [S. 32AC, 143(3)]
S. 154 : Rectification of mistake-Expenditure-Allowance-Loss of current year can be set off against income declared u/s 115BBD-Tax on certain dividends received from foreign companies-Debatable cannot be rectified. [S. 115BBD, 143(1)]
S. 147 : Reassessment-Recorded reasons not provided-Reassessment is bad in law. [S. 148]
S. 147 : Reassessment-With in four years-AIR Information-Cash credits-Cash deposit in the bank-Assessing Officer failed to make reasonable enquiry-Reassessment was quashed. [S. 44AE, 68, 148]
S. 145 : Method of accounting-Accrual of income-Real income theory-Interest income-Realisation becomes impossible-Income cannot be assessed on hypothetical basis. [S. 4, 5]
S. 143(3) : Assessment-Order passed in the name of a deceased person is invalid and sustainable in the eyes of law. [ITAT R. 27]
S. 115JB : Book profit-Capital receipt-A particular receipt cannot be assessed as book profit merely on the ground that the assessee has offered it in the return of income. [S. 2(24),4]