S.254(1): Appellate Tribunal -Duties -ITAT misdirected by going into the facts of assessment order dated 31.03.2016 when the appeal arose out of order dated 15.12.2017- Order of Tribunal was remanded for passing a fresh order after verifying the records. [ S. 148, 148, 151, 260A ]

S. 153A: Assessment – Search or requisition- Share certificate – Disclosed in the books of account – Statement of a third party – Opportunity of cross-examination not given – Order is bad in law [ S. 68, 132(4) , 133(6) ]

S. 151: Reassessment – Notice – After the expiry of four years – without proper sanction – Reassessment proceedings quashed.[ S. 148 , 151(1) ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Third party Search – Provision of section 153C is applicable – Notice under section 148A is held to be bad in law – Remanded the matter back to the AO to pass a fresh reasoned order in accordance with the law. [ S. 148, 148A(d), 153C, Art , 226 ]

S. 147: Reassessment – Principle of natural justice – Reassessment completed without providing an opportunity of being heard- Contention of alternative remedy was rejected – Order and notice was quashed and set aside [ S. 148, Art, 226 ]

S. 271(1)(c) : Penalty-Concealment-Provision of interest twice-Bonfide mistake-Deletion of penalty is justified.

S. 268A : Appeal-Tax effect less than the monetary limit of Rs 1 crore-Appeal of revenue was dismissed [S. 260A]

S. 264 : Commissioner-Revision of other orders-Appeal not filed-Rejection of revision petition is held to be not valid-Commissioner is directed to hear the petition on merits. [S. 250, Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revision was done twice-Revision for the third time is held to be not valid. [S. 143(3), 153A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Unexplained investments-Assessing Officer has not enquired into any documentary evidence-Revision was held to be justified. [S. 69]