S. 147 : Reassessment –With in four years-Reopening of assessment by succeeding Assessing Officer to disallow excess deduction was held to be change of opinion which was held to be impermissible [ S.80IA, 143(3) 148 ]

S. 147: Reassessment – Recorded reasons- Wrongly stating matters for earlier years pending before High court instead of before Tribunal being inadvertent error, does not invalidate reasons recorded for reopening of assessment — Reopening was held to be valid [S. 10A,143(1), 148 ]

S.147: Reassessment-After the expiry of four years- There was no failure to disclose all material facts – Reassessment was held to be not valid – Alternative remedy is no bar to file writ petition if the action of the authority is beyond their jurisdiction . [S. 148 ]

S.147: Reassessment-After the expiry of four years-Deemed dividend – No failure to disclose material facts hence reassessment was held to be not valid [ S. 148 ]

S. 147: Reassessment — After the expiry of four years – Failure to repatriate export proceeds with in time stipulated – Reassessment proceedings was held to be valid . AO was directed to verify the contention of the assesse on facts .[ S.10B, 148 ]

S.147: Reassessment – After the expiry of four years- Agricultural income –Change of opinion- Objection was disposed without speaking order-No failure to disclose material facts -Notice for reassessment only for the relevant year and there were hundreds of coffee growers whose income were also exempted, reopening notice issued only against assessee during relevant assessment year was unjustified .[ S.10(1), 148 ]

S.147: Reassessment-After the expiry of four years- Reopening of assessment on the ground that activities of assessee is not eligible for deduction was held to be change of opinion, hence reopening was held to be not valid [ S.80IB(8A), 148 ]

S. 147:Reassessment- Transfer pricing – Permanent establishment – Income had already been disclosed by the Indian subsidiary and found by the Transfer Pricing Officer (TPO) to be at arm’s length. Reassessment was held to be bad in law .[ S. 92C, 148 ]

S. 147 : Reassessment –Change of opinion- Deduction was allowed in the original assessment, on the same facts to hold that the excess deduction was allowed will be change of opinion therefore ,reassessment was held to be bad in law . [S.10A,148 ]

S. 145:Method of accounting – Developer –Percentage completion method – Accounting Standards AS-1, AS-7 & AS-9, the Guidance Note on Accounting for Real Estate Transactions issued by the ICAI- Percentage of revenue recognised by the CIT(A) was held to be justified. [ S. 145(2) ]