S.147: Reassessment-After the expiry of four years- Shell companies-Search of third person revealing that transaction disclosed by Assessee during original assessment was bogus — Notice is held to be valid .[ S.148 ]

S.68:Cash credits — Authorities entitled to look into surrounding circumstances to find out reality — Unable to state exact purpose for which loan of Rs. 1 Crore taken and stating her husband looked after all finances —No personal or business relationship of assessee with that party — Transaction squared in next financial year would not establish genuineness of transaction — Addition is held to be justified ( Relied , CIT v .Durga Prasad More ( 1971) 82 ITR 540 (SC) / Sumati Dayal v.CIT ( 1995) 214 ITR 801 (SC) ) [ S.131 ]

S. 43D : Public financial institutions – Mercantile system of accounting — Co-Operative Bank — Interest on non-performing assets cannot be recognised on accrual basis — Assessee bound by Reserve Bank of India guidelines.[ S.145]

S. 43(5) : Speculative transaction –Hedging-High sea sales –Not speculative-Allowable as business loss [ S.28(i)]

S.32: Depreciation — Additional depreciation — Manufacture –Ready mix concrete is an article which has been manufactured — Entitled to additional depreciation on plant and machinery used in manufacture of ready mix concrete . Transit Mixer and Trucks used to transport ready mix concrete whether plant and machinery involved in manufacture of ready mix concrete is question to be decided by Tribunal — Matter remanded. [ S.32(1)(iia) ]

Interpretation of taxing Statutes — Entries — Depreciation-Precedent – If a particular article would fall within the description by the force of the words used, it is impermissible to ignore the word description. Ratio in Bimetal Bearings Ltd. v. State of Tamil Nadu ( 1991) 80 STC 167(SC)

S.271(1)(c): Penalty – Concealment – Failure by assessing officer to specify exact charge for which penalty proceeding was initiated – Penalty quashed.[ S. 10A,115JB ]

S.271(1)(c): Penalty-Concealment- Income from other Sources-nexus not proved-Levy of penalty is justified .

S. 263 : Commissioner – Revision of orders prejudicial to revenue – revision of order u/s 153A – held, no incriminating material was found and therefore, the AO could not have made any addition – Held, therefore, the CIT erred in assuming jurisdiction u/s 263 as the order of the AO was not erroneous. [S. 153A]

S. 234B : Interest – Advance Tax – Book profits- Alternate Minimum Tax -Interest is leviable [S.115JC]