S. 153C : Assessment-Income of any other person-Search-Addition only on basis of Pen Drive seized from third party-Department failing to establish any connection either business or personal of assessee with third party-No efforts to summon third party-No Incriminating material found during search-Addition is not valid. [S. 68, 132]

S. 153A : Assessment–Search-No incriminating material found-Concluded assessments for year earlier to year of search not permissible-Binding precedent-Pendency of Special leave or dismissal of special leave cannot be ground for not following the Delhi High Court decision. [s. 132]

S. 153A : Assessment–Search-No incriminating material found-Addition is held to be not justified-Noting and jotting on loose sheet of papers–Addition is held to be not valid. [S. 69C]

S. 151 : Reassessment-Sanction for issue of notice-Approval granted in mechanical manner and without application of mind-Reopening is not valid. [S. 147, 148]

S. 148 : Reassessment–Notice–Reply stating that original return filed should be treated as return filed in repose to notice u/s. 148-Postal receipt is filed–Neither notice u/s. 143(2) is issued nor assessment completed u/s. 144 of the Act nor interest charged u/s. 234A–Reassessment is held to be not valid. [S. 139, 143(2), 144, 147, 234A]

S. 147 : Reassessment-Reason to be believe-Securities premium account–Merely on the basis of information received by another AO based on appraisal report of A group-Reassessment cannot be made. [S. 148]

S. 147 : Reassessment-Falsification of accounts–Statement of chairman–Un explained loans–Interest-Reassessment is held to be valid–Order of CIT(A) is affirmed. [S. 2(22)(e), 148]

S. 147 : Reassessment–With in four years-Depreciation at higher rate-Not examining the issue at the time of original assessment– Reassessment is held to be valid. [S. 32, 143(1)]

S. 147 : Reassessment–With in four years-Search and seizure– Alleged cash loans–Parties denying cash loans-Reassessment is held to be nor valid–Correct legal course could have been action u/s. 153C and not reassessment–Addition is deleted. [S. 132, 153A, 153C, 148]

S. 147 : Reassessment-After the expiry of four years-Survey– Difference of labour charges-No failure to disclose material facts-Reassessment is held to be not permissible. [S. 133A, 148]