S. 147 : Reassessment–With in four years-Commercial production-Every non-disclosure of material facts will not or cannot be a justifiable reason for reopening an assessment-What was required to be considered is that, substance over form-Order of single judge is affirmed. [S. 10B, 148, Art. 226]

S. 147 : Reassessment–With in four years-Issue of shares at premium-Mere production before the AO the Account Books, or other evidence, from which material evidence could, with due diligence, have been discovered by the Assessing Officer, would not necessarily amount to disclosure within the meaning of the First Proviso to S. 147–Court perused the Investigation report which was referred while issuing the notice of reassessment-Notice of reassessment is held to be valid-Writ petition is dismissed-Awarded costs of Rs. 1 lakhs to be paid to The Delhi High Court Advocates Welfare Trust. [S.68, 143(1), 148]

S. 147 : Reassessment–With in four years–Capital gains-Valuation-Reassessment is held to be valid–Referring the matter for valuation to the file of the AO is held to be valid. [S. 2(47)(v), 50C), 148]

S. 147 : Reassessment–With in four years-Tax frauds-Reasons to believe have been recorded in meticulous details by the AO-Approval was obtained before issue of notice-Notice of reassessment is held to be valid in law. [S. 148, 151]

S. 147 : Reassessment-After the expiry of four years-Unabsorbed depreciation–No failure to disclose material facts–Reassessment is held to be bad in law. [S. 32, 148, 149]

S. 147 : Reassessment-After the expiry of four years-Housing projects–Completion certificate–No failure to disclose material facts–Reassessment notice is held to be bad in law. [S.80(IB)(10), 148, Art.226]

S. 143(3) : Assessment–Direction of appellate Tribunal-Decide the issue a fresh-AO cannot go beyond the direction-Writ of the assessee is allowed. [S. 44AD, 254(1), Art.226]

S. 142(2A) : Inquiry before assessment–Special audit–Opportunity of hearing was given–Writ to quash the special audit is dismissed. [S. 142(1)]

S. 139A : Permanent account number–Petitioner would not be in default in any proceedings only for the reason that the permanent account number is not linked with Aadhaar or Aadhaar number is not quoted; and that pending the petition, the petitioner may not be subjected to the proviso to sub-section (2) of section 139AA of the Act. [S. 39AA(2), Art. 226]

S. 132 : Search and seizure–Reason to believe-Recording of satisfaction-Jewellery-Stock in trade-No cogent basis for arriving at conclusion that assessee was in possession of jewellery which represented his undisclosed income or property was discernible from satisfaction note, impugned search and seizure was to be quashed and all actions taken pursuant to such search and seizure were to be declared illegal-The respondents were ordered to pay costs quantified at Rs. 50,000. . [S. 132B, Art. 226]