S. 245D : Settlement Commission-Application–Rejection of an application on the ground that the income disclosed belonged to another entity was a finding of fact and did not call for interference by the High Court. [S.245C, Art. 226]

S. 245D : Settlement Commission-Addition was made by extrapolating the actual production vis a vis the reported production of the current year to the preceding years-Addition on the grounds of sufficient evidence of unaccounted production confirmed-Entire process to be seen for considering 80IB deduction-Writ petition was dismissed on the ground that the issue was very factual and there being no perversity. [S. 132, 153A, 80IB, 245D(4), Art. 226 ]

S. 245D : Settlement Commission – If Settlement Commission is unable to form a decisive opinion to give a definitive finding for rejection of settlement application after initial and preliminary hearing, proceeding to second stage, in which more in-depth scrutiny and verification takes place is the only option- Order of Settlement Commission rejecting the petition was set aside and directed to decide on merits. [S. 132, 245C(1), 245D(2)(C)]

S. 234B : Interest–Advance tax–Refund of warehousing charges paid on seized goods by department was rejected–Cannot claim interest from date when goods were auctioned but entitled to claim interest at 12% p.a. from the date of order passed by the settlement commission till actual payment. [S. 132]

S. 153 : Assessment–Reassessment–Limitation–Direction by CIT(A) to assess income in the hands of another person can be given only if an opportunity of being heard is given to such other person- Matter remanded to CIT(A). [S. 147, 148, 149, 150]

S. 147 : Reassessment–Notice–Expenditure on contact charges -Allegation of charges were high-Reopening on issues examined in detail in the assessment is bad in law. [S. 37(1), 69C, 148]

S. 147 : Reassessment–Notice–Not to be quashed if appeal on similar issue pending in another Assessment year. [A. 226, S. 115BBC]

S. 147 : Reassessment – Survey -Non disclosure of Royalty and FTS in the original return-Reassessment is held to be justified. [S. 133A, 148]

S. 147 : Reassessment–Notice-License fee-Use of logo -Capital or revenue – Reopening solely based on audit objections not permitted as it amounts to change of opinion. [S. 37(1), 147]

S. 147 : Reassessment–Based on subsequent finding of DRP that there was no Permanent Establishment of the assessee in India– AO dropped reassessment proceedings–Order passed by High Court upholding validity of those proceedings was to be set aside. [S. 148]