S. 10 (23C) : Educational institution-No activity carried on other than educational purposes-Exemption cannot be denied-land sold at fair market value-Approval cannot be denied-Direction of the High court was not followed-Order barred by limitation. [S. 10(23C)(vi), 12A, 147, 148]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Deemed dividend-Order was passed after considering the reply and application of mind-Revision is held to be bad in law. [S. 2(22)(3), 143 (3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Examining the issue in the course of assessment proceedings-No discussion in the assessment order-Order is not erroneous-Interpretation-Provision inserted from date in midst of financial year-Procedural aspect-Prospective in nature.

S. 158BC : Block assessment-Undisclosed Income-No incriminating material found during search-Addition cannot be made-Delay in filing return-Interest payable till date of original assessment order–No provision to charge interest beyond date of original assessment. [s. 158BFA(1)].

S. 158BC : Block assessment-Undisclosed income-Incriminating material was found-Explanation was not satisfactory-Addition was held to be justified-Limitation-Panchnama-Limitation starts only from date of third panchnama-Not barred by limitation. [S. 158BE]

S. 153D : Assessment-Search-Approval-Charitable Trust-Siphoning off of funds by founder-Approval given on same day by Additional Commissioner Stationed 250 Kms. away from Assessing Officer’s Office-No record regarding movement of files-Approval given without application of mind-Assessment null and void. [S. 10(23C) 12AA, 153A]

S. 153A : Assessment-Search or requisition-No incriminating material-Addition not sustainable-Share application money-Share premium-Identity of share holder established-Addition was held to be not valid. [S. 68]

S. 153A : Assessment-Search-Unproved expenditure-No incriminating material was found-Ad-hoc expenditure of fifty percent of expenditure is held to be not sustainable. [S.132]

S. 147 : Reassessment-Recorded reasons-No addition was made on the basis of recorded reasons-Addition was made on long term capital gains-Reassessment was not valid. [S. 148]

S. 147 : Reassessment-Information from investigation Wing-Client code modification-Recording of incorrect and wrong facts-Mechanical approval-Reassessment was not valid. [S. 148, 151]