S. 271D : Penalty-Takes or accepts any loan or deposit-Share application money received in cash-Not loan or deposit-Penalty deleted.[S.269SS]

S. 270A : Penalty-Under-reporting or misreporting of income-Excessive claim of interest expenditure-Mere disallowance on estimate-Not misrepresentation or suppression of facts-Penalty not leviable-Voluntary admission of income-Does not constitute under-reporting or misreporting-Penalty not leviable.[S.270A(9)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue Long-term capital gains-Reassessment completed after due enquiry-Principal Commissioner making no independent enquiry-Revision invalid-Purchase of immovable property wrongly treated as sale-Documentary evidence ignored-Revision invalid. [S.10(38), 45, 147]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Notice under section 143(2) not issued in prescribed format-Assessment invalid-Revision under section 263 without jurisdiction-CBDT Instruction F. No. 225/157/2017/ITA-II dated 23-6-2017.[S. 143(2), 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Protective assessment-Substantive assessment confirmed in another person’s case-Revision not sustainable-Order passed without considering assessee’s submissions-Violation of principles of natural justice-Revision quashed.[S. 143(3)]

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Cash credits-Additional evidence filed before Commissioner (Appeals) not considered-Remand report not called for-Matter restored for de novo assessment.[S.68, 69,R. 46A]

S. 153A : Assessment-Search-Undisclosed income-Construction and property development-On money-Seized diaries-Statement of senior sales manager-Extrapolation of receipt of on money-Addition was made on guesswork and surmises-Addition was deleted. [S. 131, 132, 133A]

S. 151 : Reassessment-Sanction for issue of notice-Search cases-Search assessment-Approval by Director General having jurisdiction over Central Charge-Sanction valid.-CBDT Notification No. 68 of 2014, dated 13-11-2014-Escaped income represented by asset exceeding Rs. 50 lakhs-Reopening not barred by limitation-Central Charge-Assignment outside faceless assessment scheme-Jurisdictional Assessing Officer competent to complete assessment-Seized diaries-Statement under section 132(4) admitting ownership-Subsequent plea that diaries belonged to family members rejected-Seized diaries-Tally books subsequently prepared not reliable-Profit to be determined from seized diaries-Land trading-Estimation of profit-Profit rate of 13.14 per cent. held reasonable-Share trading-Estimation of profit-Profit rate of 8 per cent. on total credits directed-Trading account (Maal Khaate)-Income estimated at 10 per cent. of total credits–Peak credit-Telescoping of income assessed in earlier years-Benefit allowable-Bad debts-Claim not reflected in seized diaries-Deduction not allowable–Accrued interest-Notional entries in seized diaries-Double taxation avoided-Addition deleted-Negative peak cash balance-Opening balances of earlier years to be considered-Matter restored-Miscellaneous cash transactions-Only undisclosed income taxable-Peak credit method upheld. [S.28(i), 36(1)(vii), 44AB,44AD, 69, 69A, 115BBE, 132, 132(4), 147, 148, 149(1)b), 153A]

S. 147 : Reassessment-Change of opinion-Reinsurance premium paid to non-resident reinsurers-No fresh tangible material-Reopening invalid.[S. 40(a)(i),148, 195]

S. 147 : Reassessment-After the expiry of four years-Disallowance under section 14A already deleted in assessee’s own case-No failure to disclose material facts-Reassessment invalid-Speculative transactions-No addition made on issue forming basis of reopening-Addition on other issues not permissible-Reassessment invalid. [S.14A,40A(2)(b), 43(5), 73 148, R. 8D]