S. 154 : Rectification of mistake-Unexplained purchases-Disallowance of 20%-Disallowance of entire purchase by passing a rectification order is held to be not valid. [S. 69C, 143(3)]

S. 153A : Assessment-Search-Share capital-Items already disclosed in original return and balance sheet-In absence of recovery of any incriminating material for making said addition in hands of assessee, said addition was to be deleted. [S. 68]

S. 153A : Assessment-Search-Several incriminating materials were found during course of search-Assessing Officer can interfere with original assessment while making assessment. [S. 143(1)(a)]

S. 147 : Reassessment-Sales promotion expenses-No new information-Reassessment is held to be bad in law. [S. 37(1), 148]

S. 147 : Reassessment-Under invoicing-Cash credits-Report of commission- Reassessment proceedings initiated merely on basis of report of a Commission appointed by Central Government that there was under invoicing of exports-Held to be bad in law-Pronouncement of order-Period during which lockdown was in force in country due to COVID 19 pandemic was to be excluded. [S. 68, 148, 255, ITAT R. 35]

S. 147 : Reassessment-Internal audit objection-Reimbursement of expenses-Failure to deduct tax at source-Reassessment is held to be not valid-90 days time period permitted under Rule 34(5) for pronouncing order was to be computed by deducting Covid-19 pandemic lockdown period. [S. 40(a)(ia), 148, 195, 255, ITATR. 34(5)]

S. 145 : Method of accounting-Rehabilitation and implementation of water supply-Percentage of contract method adopted by the assessee is held to be justified.

S. 145 : Method of accounting-Rejection of books of account without providing an opportunity is held to be not valid-Cash credits-Rejection of documents without any reason is held to be not justified-Matter remanded. [S. 68]

S. 143(3) : Assessment-Amalgamation-Succession to business otherwise than on death-Amalgamating company was not in existence at time of conduct of assessment proceedings as well as on date of passing Assessment Order-Assessment Order passed in name of amalgamating company being void ab initio was to be set aside. [S. 170, 292B]

S. 115JB : Book profit-Computation for purpose of clause (f) of Explanation 1 to section 115JB(2) is to be made without restoring to computation as contemplated under section 14A, read with rule 8D. [S. 14A, R. 8D]