S. 244A : Refunds – Interest on refunds–Entitle to interest on excess self assessment tax from date of payments till refund. [S.14OA, 244(1)(b)]

S. 237 : Refunds–Application for refund of excess amount paid is rejected–Remedy of revision application is maintainable-Writ is not maintainable. [S.197, 246A, 264, Art. 226]

S. 153C : Assessment-Income of any other person-Search–No incriminating material or document found during the course of search- Deletion of addition is held to be justified.[S. 132, 144]

S. 147 : Reassessment-Change of opinion- Business expenditure- Vacancy allowance-Expenditures for maintaining skilled staff for keeping machinery intact, minimum amounts to be paid for retaining electricity connection and so on during such period so as to keep machinery ready for use and assessee also commenced it manufacturing activities in subsequent year- Reassessment is held to be not valid-Vacancy allowance which was not claimed in the original assessment proceedings cannot be claimed in reassessment proceedings. [S. 22, 23, 37(1)]

S. 147 : Reassessment-Dropping of reassessment proceedings by AO- Absence of challenge by the assseee–Held to be justified. [S.148, Art.226]

S. 147 : Reassessment-Assessment u/s. 143(1) can be reopened on basis of information obtained during course of assessment of earlier assessment year under S. 143(3) of the Act. [S.143(1), 148, Art.226]

S. 147 : Reassessment-Information received from Investigation wing– Accommodation entries-Share capital-Failure to examine in original assessment proceedings–Reassessment notice is held to be valid. The assessee was permitted to raise its objections in the light of the documents provided by the respondent in court within seven days. The Assessing Officer shall decide the objections that may be raised within two weeks.. [S.68, 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Stock in trade – Debit of purchase of traded goods-In the original assessment proceedings profit and loss account was thoroughly scrutinised by the AO-No failure to disclose on part of assessee to produce all material particulars during original assessment proceedings-Notice for reassessment is held to be not valid. [S. 68, 148, Art. 226]

S. 147 : Reassessment–After the expiry of four years- Information from DDIT (investigation)–Purchasing and selling of shares- Systematic evasion of taxes by clients by misuse of NMCE platform–Reassessment notice is held to be justified. [S.143(1), Art.226]

S. 144C : Reference to dispute resolution panel – E-proceedings facility – Manual mode- Period of limitation- Receipt of a draft assessment order in manual mode had to be seen as date of draft assessment order- Judgement is peculiar factual circumstances, hence not to be cited as a precedent in subsequent cases. [S. 92C, Art.226]