S. 147 : Reassessment –Order passed consequent to reassessment had not confirmed the addition attributable to the reasonable belief of the Assessing Officer, while passing the reassessment order – Reassessment is held to be bad in law.[ S.148 ]

S. 147 : Reassessment – Change of opinion- Income from other sources -AO has consciously considered the claim for deduction u/s 80IC in the regular assessment proceedings – Accordingly reassessment is held to be not valid .[ S.80IC, 148 ]

S. 147 : Reassessment – Export oriented undertakings – Where in the course of original assessment proceedings the Assessing Officer has raised several queries and allowed the claim-Reassessment cannot be made to examine another facet of said claim.[ S.10B, 148 ]

S. 12AA : Procedure for registration –Trust or institution- In the absence of any cogent material or evidence to establish any violation of provisions of S. 12AA(3),cancellation of registration retrospectively is held to be not justified [ S.11, 12AA(3) ]

S. 4 : Charge of income-tax -Capital-Revenue- Amount received by assessee from assigning its business rights is held to be capital receipts . Amount is also not to be included in computing book profits . [ S.155JB, 263 ]

S. 69 :Unexplained investments -Investment in immovable property- Merely on the basis of statement u/s 132(4) during the course search proceedings additions cannot be made- Order of Tribunal deleting the addition is affirmed . [ S.132(4) ]

S. 69A : Unexplained money – Income from undisclosed sources – Merely on the basis of confessional statement made by third party under Maharashtra Central organised Crime Act, 1999(MOCA) stating that certain payment was made to the assessee ,without any corroborative evidence , deletion of addition held to be justified .[ S.132, Maharashtra Central organised Crime Act, 1999 S.18 ]

S. 271G : Penalty – Documents – International transaction – Transfer pricing – A specific finding should be recorded on date by which assessee was required to furnish documents and whether said documents were furnished with in specified date – Deletion of penalty is held to be justified [ S.274 ]

S. 271(1)(c) : Penalty—Concealment-No order of imposing or enhancing or reducing or cancelling penalty or dropping proceedings for imposition of penalty shall be passed unless assessee is heard or has been given a reasonable opportunity of being heard and after expiry of six months from end of year of which order of appellate authority has been received by Commissioner. [S. 275 (IA)]

S. 234E : Fee-Default in furnishing the statements- No enabling provision to impose fees for late filing of return or statement of TDS prior to 1st June, 2015–AO had no jurisdiction to levy fees under section 234E if intimation issued prior 1st June, 2015. [S. 200A]