S.147: Reassessment — Accommodation entries -Non application of mind -Merely on the basis of DIT(Inv.) without verification , reassessment is held to be bad in law [ S.148 ]

S. 143(2) : Assessment – Notice – One return is filed pursuant to notice issued u/s 148 , issue of notice u/s 143(2) is mandatory .[ S. 139,144, 148 ]

S. 80HHC : Export business -Income from job working of machining -Income to be considered as business income.

S. 68:Cash credits — Source of cash deposit was not explained satisfactorily-Addition was held to be justified .

S.68:Cash credits — Burden of proof — Mere confirmation is not sufficient, identity , creditworthiness and genuineness was not proved – Addition was held to be justified .

S. 45(2) : Capital gains – Conversion of a capital asset in to stock-in-trade -Capital gains to be computed on sale up to date of conversion of Land into stock- in-trade and profit on sale of stock in trade to be assessed as business income or loss. Capital gains to be set off against business loss [ S.28(i) ]

S.40(a)(ia):Amounts not deductible – Deduction at source – Professional fees – Failure to deduct tax at source – Disallowance was held to be justified .

S. 10AA : Special economic zones – Industrial undertaking- Investment in Plant and Machinery for new unit was substantial compared to value of machinery shifted — Entitled to exemption.

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Services of Crew under separate agreement – Matter remanded to Tribunal -DTAA -India- Germany [ S. 10(15A),Art, 111]

S. 4 : Charge of income-tax -Capital or revenue —Business of real estate -Compensation received under Arbitration Award is held to be capital receipt .