S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment not valid-Accumulation of income-Claim that 15 Per Cent. of gross receipts should be allowed to be carried forward and up to 85 Per Cent. of gross receipts required to be applied in a year-Corpus donation-Excess application of preceding assessment year can be set off against current year’s receipts. [S. 11, 148]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Audit objection-[S. 40(a)(ia), 143(3), 148]

S. 147 : Reassessment-After the expiry of four years-Bogus purchase-No disallowance made on account of bogus purchase-Reassessment proceedings quashed. [S.69C, 148]

S. 145A : Method of accounting-Valuation-Closing stock-Assessing Officer taking average mark-up of 25 Per Cent.-Directed to take average mark-up of 32 Per Cent. to arrive at cost price of closing stock as on date of search. [S. 132]

S. 145A : Method of accounting-Valuation-Sales Returns-No Provision created-Sales return policy accounted based on sound accounting principles-Deletion of addition is proper.

S. 145A : Method of accounting-Valuation-Closing Stock-Valuation-Jewellery business-“Last In First Out” System of Accounting-Consistently valuing its stock of jewellery under “Last In First Out”-Order of CIT(A) is affirmed. [S. 145]

S. 145A : Method of accounting-Valuation-Under valuation of stock-Value of opening stock lower than admitted during survey-Value of opening stock of finished goods higher than average rate-Entire exercise of valuation adhoc and without any basis-Adjustment too minor to hold assessee attempted undervaluation of stock-Additions not justified.[S.133A]

S. 145A : Method of accounting-Contract receipts-Net of service tax-Exclusive method for accounting-Deduction not claimed-No disallowance can be made. [S. 43B, 145A(a)(ii)]

S. 145 : Method of accounting-Accrual of Liability-Octroi expenses-Accrual of income-Incentives-Amortization of only part payment in profit and loss account-Addition made after reducing part payment accounted for by assessee-Proper-Sales return policy accounted based on sound accounting principles. Deletion of addition by Commissioner (Appeals) is proper.

S. 145 : Method of accounting-Accrual of income-Entitled to receive cold storage charges only on preservation of potatoes in good, marketable condition up to that time-No accrual of cold storage charges over time or right to receive them in part performance of contract-Income for business cycle February to November did not accrue to assessee during February-March-No adjustment for contract period February to November to be made for year ending March-Direct input cost of provision of cold storage charges relating to February and March to be kept in abeyance to be claimed in following year.[S. 4, 5, 37 (1)]