S. 194C : Deduction at source–Contractors-Payment made to farmers for purchase of sugarcane as harvesting charges-Not liable to TDS-No disallowance can be made. [S. 40(a)(ia)]

S. 194C : Deduction at source–Contractors-Finance Act states that it would be applicable from a particular date–Section cannot be applied retrospectively. [S. 40(a)(ia), 194(6), 263]

S. 153C : Assessment-Income of any other person–Search Seized documents not belonging to assessee-No incriminating documents / materials seized–Addition cannot be sustained.

S. 153A : Assessment–Search-Time limit for issue of notice u/s.143(2) and completion of assessment already lapsed as on date of search-An addition is unsustainable. [S. 143(2)]

S. 153A : Assessment–Search-Assessee was not in existence at time of first search–No documents found in second search belonging to assessee-Payment of interest on post-dated cheques outside books beyond six months from sale deed-No addition could be sustained.

S. 151 : Reassessment-Sanction for issue of notice-Approval of commissioner in a mechanical manner without due application of mind and mentioning only “yes”-Reassessment is not sustainable. [S. 147, 148]

S. 147 : Reassessment–Reopening on same issue merely for making fishing or roving inquiries is impermissible in law. [S. 148]

S. 147 : Reassessment–Notice-Notice was neither served upon assessee nor sent at proper address–Reassessment is held to be not valid. [S. 148]

S. 147 : Reassessment-Reopening without jurisdiction-Non recording of satisfaction that income has escaped assessment by reason of failure on the part of Assessee to disclose material facts and hence quashed reopening proceedings.[S. 148]

S. 147 : Reassessment-Reasons recorded and additions made–CIT(A) deleted some additions which formed part of reasons–other additions not part of reasons survived-held no other addition could survive in respect of which reasons are not recorded. [S. 148]