S.147: Reassessment-AO recorded reasons mechanically on information received from Investigation Wing-Unexplained money-Search-No direct nexus-Reassessment notice and order disposing of the objection were quashed and set aside-Order of High Court affirmed-SLP of revenue dismissed. [S.69A, 148, 151, Art. 136]

S. 147: Reassessment-Unexplained investments-Investment in shares-Interest on borrowings-Security premium-Reassessment was quashed by the High Court-SLP is dismissed on account of delay of 498 days. [S. 14A, 69, 148, Art. 136]

S.147 : Reassessment-Cash credits-High Court held that where information regarding assessee’s trades in shares was already available on record at the time of original assessment, reopening of assessment on said ground was invalid as it was not reason to believe but reason to suspect-SLP of revenue dismissed. [S. 68, 148, Art. 136]

S.147: Reassessment-After expiry of four years-No failure to disclose material facts-Change of opinion-Dividend from trust-Investment allowance wrongly claimed-Reopening invalid-SLP of revenue dismissed. [S. 2(22)(e), 10(34), 32AC, 115-O, 143(3), 148, Art.136]

S. 145: Method of accounting-Mercantile-Accrual-Time share membership fees-Matching principle-Membership fee received upfront could be deferred and recognised as income over tenure of membership contract, applying matching principle, notwithstanding mercantile system and absence of express statutory provision to defer revenue, and despite separate collection of annual maintenance and utility charges-Order of tribunal affirmed. [S. 4, 5, 28(i), 260A]

S. 144C: Reference to dispute resolution panel-Final assessment order could not be treated as a draft assessment order, nor could the defect be cured by remanding the matter to the Assessing Officer for passing a fresh draft assessment order-Order was quashed. [S.143(3), 144B(1)(xxi), Art. 226]

S. 144B: Faceless Assessment-Non-compliance with mandatory procedure-Draft assessment order-Assessment order was quashed and set aside. [S.144B(1)(xvi), Art. 226]

S. 143(3): Assessment-Amalgamation-Intimation of amalgamation was sent to the Assessing Officer-Non-existing entity-Assessing Officer committed jurisdictional error by issuing notices and passing assessment order in name of a non-existent entity-Assessment order is void and bad in law. [S. 143(2), Art. 226]

S. 143(3) Assessment-Merger-Additional evidence-Non-existent company-Additional grounds and evidence admitted by High Court-Order of assessment was quashed-SLP of revenue was dismissed.[S.260A, Code of Civil Procedure, 1908, Order 41, Rule 27, Art. 136,Art, 136]

S. 132A: Powers-Requisition of books of account-Warrant of authorisation-Cash and silver from Police authorities-Pendency of appeal before High Court-Writ petition dismissed. [S. 132 Art. 226]