S. 151 : Reassessment-Sanction for issue of notice-Approving authorities giving approval in mechanical manner-Reassessment invalid-Department failing to bring on record any evidence of income earned by assessee-Entire amount of doubtful transactions added as assessee’s additional income-Impermissible. [S. 147, 148]

S. 147 : Reassessment–Information obtained from the sales tax department–No independent enquiry or application of mind-Reassessment invalid-Assessment–Notice-Issuance of notice u/s. 143(2) is mandatory – Failure renders the reassessment invalid [S. 69C, 143(2), 148]

S. 147 : Reassessment-Income from other sources–Reassessment proceedings initiated on suspicion-when nothing incriminating was found to suggest that anything over and above Re. 1 per share was paid by assessee-Reassessment is held to be invalid. [S.56(2)(viia), 148]

S. 147 : Reassessment–Reassessment proceedings initiated without any application of mind and examination of information received from investigation wing amounts to borrowed satisfaction–Notice is quashed. [S. 148]

S. 147 : Reassessment–Legal representatives-Notice issued in name of deceased assessee-No subsequent notice issued on legal heirs of deceased assessee-Reassessment is not valid. [S. 148, 159]

S. 147 : Reassessment-Jurisdiction of authorities-No specific order passed by principal CIT under section 120(4)(B) authorising Joint Commissioner to act as an AO-Reassessment Order passed by Joint Commissioner liable to be quashed. [S. 2(7A), 120(4)(b), 148]

S. 147 : Reassessment-After the expiry of four years-AO should record ‘reason to believe’ that certain income chargeable to tax has escaped assessment–This belief should be based on independent enquires/application of mind and not on borrowed satisfaction ie basis information from Investigation Wing- Sanction-Sanction granted by the CIT under S. 151 by simply writing “Yes, I am satisfied” is also invalid. [S. 147, 148]

S. 147 : Reassessment-After the expiry of four years–No scrutiny assessment–Reopening solely based on information from Investigation Wing–No independent application of mind– Reassessment is held to be invalid. [S. 148]

S. 145 : Method of accounting-Adjustment on account of MODVAT credit has to be made in respect of closing stock, opening stock, purchases and sales.

S. 145 : Method of accounting-Rejection of books of account-No allegation from department that books of account of assessee either incorrect or incomplete-Gross profit ratio of one year not be applied to another year for determining profit of some of transactions of another year-Rejection of books is not justified. [S. 144]