S. 263 : Commissioner-Revision of orders prejudicial to revenue-Loss-Set Off-Business or Speculation Loss-Income or loss from similar transaction held to be from business in earlier years-Change of opinion-Revision invalid. [S. 143 (3)]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Loss-Set Off-Business or Speculation Loss-Income or loss from similar transaction held to be from business in earlier years-Change of opinion-Revision invalid. [S. 143 (3)]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limitation-Order passed in consequence of direction of High court in writ proceedings-Order passed beyond period of twelve months-Assessing Officer did not have jurisdiction to frame assessment-Revision is bad in law. [S. 92CA, 143(3) 144C, 153(5) 153(6), 260]
S. 158BFA : Block assessment-Penalty-No incriminating material found or seized-Estimate of income-Benami transaction-Failure to record satisfaction-Levy of penalty is not valid. [S. 158BC, 158BF(2)]
S. 147 : Reassessment-Search and seizure-Share application money-Assessment third person-Opportunity to cross-examine alleged entry providers not provided-Reopening solely on unverified, unrectified, unsubstantiated and unconfirmed statements of third parties-Not valid. [S. 131(1)(d), 132(4), 148, 153C]
S. 147 : Reassessment-Cash credits-Assessing Officer accepting objections and not assessing income which was basis of notice-Not entitled to assess income under some other issue independently. [S. 68, 148]
S. 147 : Reassessment-Failure to dispose objections by passing separate order-Reassessment not valid-Tax effect less than 20mlakhs-Appeal of revenue dismissed. [S. 143(3), 148]
S. 147 : Reassessment-After the expiry of four years-Change of opinion-Borrowed satisfaction of Investigation wing-Reassessment is bad in law. [S. 143(3), 148, 153A]
S. 145A : Method of accounting-Valuation-Valuation of closing stock-Hypothecation-No difference in quantitative details of stock furnished to bank and those maintained in books of account-Deletion of addition is held to be justified.
S. 143(2) : Assessment-Notice Issue of notice prior to filing return of income-Order invalid. [S. 147, 148]
S. 115JB : Book profits-Computation-Expenses on initial Public Offer-Assessing Officer to consider book profits as per treatment given in finalisation of accounts.