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-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)]