S. 251: Appeal-Commissioner (Appeals)-Powers-Jurisdiction-Valid order of transfer-Matter remanded to the file of CIT(A) to decide the issue of jurisdiction. [127 (1), 127(3), 144, 147, 148]

S. 206C: Collection at source-Trading-Clubbing of income-Credit must be given-AO is directed to give due credit of TDS/TCS of the minor child in the hands of the assessee-Amendment in Finance Bill, 2024 regarding credit of tax collected to be given to persons other than collectee should be held as retrospective in nature and not to detriment of assessee against a legitimate claim [S.64(IA)]

S. 154: Rectification of mistake-Mistake apparent from the record-Enhancement of income-Inadvertent misreporting of income in the return-Affidavit filed by the chartered accountant-The affidavit and the facts stated therein require verification; the order of the CIT(A) is set aside, and the matter is restored to the AO. [S.143(1)]

S. 153A: Assessment-Search-Undisclosed income-Purchases cannot be disallowed as bogus by relying on some oral statements recorded behind the back of the assessee-No addition could be made on the basis of such documents which were not found in the control and possession of the assessee-Addition deleted.[S. 69]

S. 153A: Assessment-Search-Undisclosed income-Statement retracted-Two agreements relating to same property-No incriminating document is found-Addition cannot be made.[S. 132(4)]

S. 153A: Assessment-Search-Seized electronic material coupled with the statement given by the accounts manager of the assessee under s. 132(4) constituted incriminating material-Objection for validity of jurisdiction was rejected-Undisclosed income-Rejection of books of account justified-Estimated the profits of the assessee @ 2.21 per cent of the turnover was affirmed-Unaccounted sale proceeds could be telescoped towards the source of unaccounted expenditure and therefore, no separate addition on this account was permissible. [S.132, 132(4)]

S. 153A: Assessment-Search-Valid information-Proceedings are valid-Cash credits-Gift-Grandmother-No source to substantiate the gift-Addition was affirmed-Unexplained expenditure-Household expenses-Addition was affirmed.[S.68, 69C]

S. 153A: Assessment-Search-Tribunal cannot examine the legality of the search once the warrant and Panchnama were drawn on the assesse-Incriminating material-Unabated and concluded assesments-No addition can be made without incriminating material-Dairy was found in the premises of the director-Revenue failed to establish that the contents of entries discovered from a third person with the assessee-company-No addition can be made.[S. 132, 132(4),292C]

S. 149: Reassessment-Time limit for notice-Time-limit of four years from the end of the relevant assessment year, i.e., 2015-16, expired on 31st March, 2020, and the period of six years from the end of the relevant assessment year expired on 31st March, 2022-Notice under S. 148 was issued on 29th July, 2022, i.e., 34 days after the balance time period-Barred by limitation-Reassessment proceedings and assessment order passed are quashed.[S. 147, 148, 148A(b)]

S. 148:Reassessment-Information-Internal audit memo-notice issued under s. 148 on 29th June, 2021, was deemed to be a show-cause notice issued under s. 148A(b)-The internal audit memo was outside the scope and ambit of the term “information” as provided in Expln. 1 to s. 148 prior to its amendment by the Finance Act, 2022-Order of the CIT(A) quashing the reassessment proceedings was upheld [S. 147, 148A(b)]