S. 245D : Settlement Commission–Bogus share capital and share premium-Failure to make full and true disclosure with regard to undisclosed income by way of bogus share capital and share premium and also manner of earning such income- Settlement Commission is justified in rejecting settlement application on such ground even at stage of passing of final order under 245D(4)-Limitation-Proceedings were pending from 26-2-2015 till 4-8-2016, said period was to be excluded while calculating limitation period for issuing notice under section 143(3) read with section 153A and after excluding above period, notice issued under said section was not time barred. [S. 132, 153A, 153B, 245C, 245D(4), 245HA]

S. 226 : Collection and recovery-Modes of recovery–Joint savings account with husband-TRO cannot issue notice to bank for marking said bank account for lien towards arrears of tax liability of her husband, without issuing a notice to assessee. [S. 226(3)(iii), Art.226]

S. 153C : Assessment-Income of any other person-Search Search prior to 1-6-2015-S.153C as amended W.E.F. 1-6-2015 is not applicable-Limitation-Notice issued for the assessment years beyond six assessment years would be beyond jurisdiction- Writ is maintainable. [S. 132, 153A, 153B, Art. 226]

S. 147 : Reassessment –With in four years-Transfer of leasehold rights- Allegation that the transaction is not genuine–No new material-Reassessment is held to be not valid. [S. 45, 56, 148]

S. 147 : Reassessment-Export business-No new material-Notice under direction of Commissioner-Reassessment is held to be not valid. [S. 80HHC, 148]

S. 147 : Reassessment–With in four years-Report of investigation wing showing over valuation of shares–Original assessment u/s. 143(1)–Notice on the ground of over valuation shares is held to be valid. [S. 143(1), 143(3), 148]

S. 147 : Reassessment-After the expiry of four years-Capital gains-Year of taxability-No new material–Reassessment is held to be not valid. [S. 45, 148]

S. 147 : Reassessment-After the expiry of four years-Furnishing all details in response to notices-Non-application of mind by assessing officer to materials produced at the time of original assessment-Reassessment is invalid. [S. 142(1), 143(2) 148, Art. 226]

S. 145 : Method of accounting–Valuation of stock–Goods ready for shipment had not been transferred-Declaration made in accordance with provision of sales tax is not relevant for the purpose of income-tax Act-Valuation of stock at cost or market price at the option of assessee-Held to be valid.

S. 145 : Method of accounting–Not maintaining of stock record-Rejection of books of account is held to be valid-CIT(A) has the power of enhancement after giving an opportunity of hearing-No substantial question of law.[S. 145(3), 251]