S. 147 : Reassessment-Search in third party premises-Sale of land-Unexplained investment-Return was not filed-Reassessment notice issued after analysing voluminous material collected by revenue during search-Reassessment notice is held to be valid-Search undertaken prior to 1-6-2015-Argument that proceedings should have been initiated u/s 153C and not under section 148 was not accepted. [S. 69A, 132, 133A, 148, 153C, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Income from lease rental-Reassessment based on documents accompanying return of income-No new material discovered-Reassessment is bad in law-With in four years-Reassessment based on discrepancies noted in value of land and doubtful debts in the statement of the computation of income and financials-Reassessment is held to be valid. [S. 36(1)(viia), 69A, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Information from District Registrar-Purchase of land at higher value-Unexplained expenditure-Reassessment is held to be justified. [S. 69C, 148, Art. 226]

S. 143(3) : Assessment-Computation of capital gains-Valuation of property-Alternative remedy-Writ petition was dismissed. [S. 45, 50C, 55A, 246A, Art. 226]

S. 139 : Return of income-Extension of time for filing-Audit report-Govid-19-Impossibility for tax practitioners to complete audit work-CBDT was directed to take decision on extension of date. [S. 44AB, Art. 226]

S. 80IA : Industrial undertakings-Infrastructure development-Non-automatic approval-Requirement that a unit not to occupy more than 50 per cent of area did not apply-Entitle to deduction.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Commission paid-Export of software-Not liable to deduct tax at source-DTAA-India-Switzerland. [S. 5(2), 9(1)(vii), 195, Art. 12]

S. 37(1) : Business expenditure-Sales commission-Failure to prove service rendered-Disallowance is held to be justified.

S. 37(1) : Business expenditure-Compensation paid to employee through trust-Allowable as revenue expenditure. [S. 36(1)(iv), 36(1)(v), 40A(9)]

S. 32 : Depreciation-Road developed and maintained by it-Entitle to depreciation at 10 percent-Depreciation on Lease hold rights in land-Matter remanded back to Assessing Officer with the direction to analyse contents of agreement entered in to between assessee and SIPCOT and not go merely by nomenclature or title of document.