S.147: Reassessment – After the expiry of four years – Undisclosed investment – Valuation of shares – All facts were disclosed in the original return- Reassessment notice for valuing the shares at Rs. 35 as per Govt valuer’s report as against the purchase value of Rs. 10 per share, though the value as per rule 11U was less than Rs. 5 per share .Reassessment proceeding is stayed by passing interim relief in terms of prayer clause (d) of the Act .[S. 56(2)(vii),69B, 148, R.11UA ]

S. 4 : Charge of income-tax -Accrual- Contractor- Income in respect of sale of flats is accrued when possession was given of the flat and not when the allotment letter was issued [ S.145]

S.271(1)(c ) : Penalty -Concealment -Non specification of limb in notice levy of penalty is held to be bad in law .

S. 153A : Assessment – Search -No incriminating materials found during the search and original assessment having been completed ,addition cannot be made . [ S. 132 ]

S.153A : Assessment – Search- On the date of search the company does not existed as it was merged with another company , hence the notice and assessment is held to be bad in law .

115JB : Book profits -Amount with drawn form general reserve is to be considered while arriving at book profit.

S.115JB : Book profits -Provision of doubtful debts reduced from amount of debtors, amount of write off as bad debts cannot be added to the net profit for the purpose of arriving book profit .

S. 115JB :Book profits- Retention money cannot be treated as income for purpose of book profit though the amount is credited in the P& Loss account .[S.2(24) ]

S.68 : Cash credits : Share application money – No adverse material was found in the course of search proceedings, hence addition was held to be not justified [ S.153A ]

S.68 : Cash credits – Shell companies – Share premium – AO has not investigated the financial activity of companies which have invested in shares hence the matter was remanded to the file of AO.