S. 153A: Assessment-Search-Income from undisclosed sources-Hotel business-Cost of construction of hotel building-Valuation referred to Departmental Valuation Officer-Difference in value cannot be added as undisclosed income-Rejection of books of account-Addition is not justified-Business loss-Carry forward-Allowed current year business loss and carry forward thereof for set off in subsequent years.[S. 69, 145 (3)]

S. 153A: Assessment-Search-Assessment completed-Prior to date of search-No incriminating material-Addition is bad in law-Fresh claim cannot be entertained-Assessments for years for which assessments abate-Assessee can lodge new claim not made in regular return of income-Statement-Retraction-Merely on the basis of statement addition cannot be made, if assessee shows he was wrong on facts he admitted. [S. 139,143(3)]

S. 151 : Reassessment-Sanction for issue of notice-Joint Commissioner had merely written “Yes, I am satisfied” and not that “It is a fit case for issue of notice under Section 148”-Approval mechanical and not valid. [S. 148, 151(2)]

S. 147 : Reassessment-Moratorium in force-Liquidation-Insolvency and Bankruptcy laws-Code has overriding effect over provisions of Act-CIT(A) is wrong in not adjudicating matter on merits-Matter restored to Commissioner (Appeals) for disposal on merits after affording assessee opportunity of hearing through Liquidator. [S. 147, 148, 178(6), (Insolvency and Bankruptcy Code, 2016,S. 14, 33(5), 53, 238]

S. 147 : Reassessment-Survey-Formation of belief of income escaped assessment on wrong facts-Non application of mind-Reason stated non filer-Record shows return was filed on due date-Reassessment notice and consequential order is held to be invalid.[S. 133A, 148]

S.147: Reassessment-After the expiry of four years-Additional ground-No failure to disclose material facts-Deemed dividend-Current transactions-Accumulated profits-Closing credit balance to be verified-Reassessment is bad in law. [S. 2(22)(e), ITAT R. 27]

S. 145 : Method of accounting-Change of method-Advance tax-Interest-Matter remanded. [S. 234A]

S. 145 : Method of accounting-Charge of income-tax-Firm off Chartered Accountants rendering professional Services-service tax-Difference between gross receipts as per Income-Tax Return and service tax cannot be treated as income-Diversion by overriding title-Payments to retired partners and spouses of deceased partners in accordance with clauses of partnership deed-Cannot be assessed as income-Deduction of tax at source-Direction of CIT(A) is held to be proper. [S. 4, 5, 37(1)]

S. 144 : Best judgment assessment-Development of property-Housing project-Work-in-progress-Prescribed Accounting Standards-Addition made on estimated value, without substantial evidence to contradict actual cost recorded is not Justified. [S. 142A, 145(3)]

S.143(3): Assessment-Unexplained investment-Difference between value of closing stock furnished to bank and that shown in books of account-Value in books higher-Higher gross profit offered to tax-No defect pointed out in books of account-No Suppression of profits-Addition is not justified.[S. 69, 145]