S. 147 : Reassessment-After the expiry of four years-Faceless Assessment-Best judgment-Statement of accommodation entry provider-Search and seizure-Bogus financial transactions-No live nexus between material relied and belief formed-The name of the assessee was not mentioned in the statement recorded-Reasons recorded cannot be supplemented by assessment order or affidavit-Best judgement assessment-No relevant material with the Assessing Officer-Assessment order is quashed. [S. 132(4), 144, 144B 147, 148, Art.226]

S. 147 : Reassessment-With in four years-Capital gains-Transfer-Redemption of preference shares-Loss-No new material-Reassessment-Reassessment notice and order disposing the objection is quashed-SLP of Revenue is dismissed. [S. 2(47) 47(iv) 148, Art. 226]

S. 144C : Reference to dispute resolution panel-Eligible assessee-Assessment-Limitation-Draft assessment order-No variation in income-Barred by limitation-Order of Tribunal is affirmed-DTAA-India-Cyprus-[S.144C(15)(b)(ii)), art. 11]

S. 143(3) : Assessment-Search and seizure-Procedure laid down by Digital evidence Investigation Manual by Central Board of Direct taxes-Mandatory-Search warrant defective-Search violative of Rule 112-Digital data evidence collected by the Revenue from unknown locations without any valid search warrant and without following the guidelines issued by the CBDT vide Digital Evidence Investigation Manual-Not given an opportunity of cross examine the witness-Circulars issued by the CBDT is binding on all Income tax Authorities-Assessment order is quashed.[S.119, 143(3), R.112, Art. 226]

S. 143(3): Assessment-Person-Company-An Assessee to be assessed for income tax must be a person in existence-A company is a juridical person but the moment it is struck off from the Register of Companies and is dissolved, it ceases to exist and no assessment can be made against a dead person. [S. 2(31)(iii), 2(31(vii), 179,226(3) Companies Act, 1956, S.560(5), 560(7), Companies Act, 2013, S. 248, 250]

S. 80HHC : Export business-Profits-Interest earned on deposits and advances not entitled to deduction. [S.260A]

S. 80G : Donation-Application for approval of institution-Genuineness of activities are not in doubt-Quantum of charitable activities cannot be the basis for granting approval-Order of Tribunal directing to grant the approval is affirmed. [S.80G(5). R.11AA]

S. 68 : Cash credits-Share application money-Identity, creditworthiness and genuineness of transaction established-Order of Tribunal deleting the addition is affirmed.[S. 260A]

S. 68 : Cash credits-Share application money-Test of creditworthiness and genuineness failed to prove-Addition is affirmed.[S.260A]

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Non-Resident had no Permanent Establishment in India-Non-discrimination clause in Double Taxation Avoidance Agreement applicable-Disallowance is not justified-Provisions of agreement more beneficial to assessee is applicable-DTAA-India-Japan-United States of America.[S.9O, 195, art. 24(3), 26(3)]