S.147: Reassessment – After the expiry of four years – Change of opinion- Internal audit – Failure to dispose of objections – Reopening of assessment based on change of opinion and internal audit objections is without jurisdiction – Notice is quashed. [S. 147, 144B, Art. 226]

S. 69C : Unexplained expenditure – Sales tax department – Non genuine supplier – Failure to produce bank statements – The order of the Tribunal estimating the income at 12. 5% of alleged bogus purchases is reversed insofar as the purchases from two parties and order of the Assessing Officer making 100% of addition under Section 69C of the Act is affirmed . [ S.133(6), 260A ]

S. 279 : Offences and prosecutions – Sanction – Chief Commissioner – Commissioner -Compounding application filed beyond 36 months from the date of filing of complaint- Rejection of application- CBDT guidelines are not statute -Rejection of compounding application is quashed – Commissioner is directed to consider all facts and circumstances and decide whether such facts make out the case for exercising discretion in favour of compounding the offence. [ S. 279(2) , Art. 226 ]

S. 69C: Unexplained expenditure – Bogus purchases –Information from Sales- Tax Department – Failure to prove genuineness of purchases – Addition is justified –Order of the Appellate Tribunal holding that only profit estimation at 12. 5% can be made is set aside – Order of the Assessing Officer is affirmed . [S. 133(6), 143(3), 144, 147, 148, 260A]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-Deletion of concealment penalty-Concealment-Acquittal by Trial Court-Presumption of innocence of accused-Appeal against acquittal is dismissed. [S.271(1)(c), 277]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-Concealment of income-Deletion of penalty-Prosecution is not valid. [S. 271(1)(c),

S. 276B : Offences and prosecutions-Failure to pay to the credit tax deducted at source-Compounding of offences-Application for compounding-Delay in application-Discretion of authority to condone delay should be exercised in judicious manner. [S. 279]

S. 254(2A): Appellate Tribunal-Stay-Cash credits-Prescribing 20 Per Cent. predeposit of demand is justified-Order of Tribunal is sustained.[S.68, 220(6), Art. 226]

S. 254(2A): Appellate Tribunal-Stay-Cash credits-Prescribing 20 Per Cent. predeposit of demand Income-Tax-Thirty Per Cent. of demand paid by assessee-Order of High Court is modified granting stay of recovery pending appeal to Tribunal-Tribunal is directed to decide appeal on merits without being influenced by observations of High Court.[S. 68, 220(6), Art. 136]

S. 246A : Appeal-Commissioner (Appeals)-Stay of demand-Not proved prima facie case-Condition of pre deposit of 20 Per Cent. of demand for grant of stay discretionary-Financial stringency not proved-Writ petition is dismissed. [S. 156, 220 (6), Art. 226]