S. 153A: Assessment-Search-Information from Investigation wing-Foreign Bank-The assessee has accepted the relevant documents as genuine-Not necessary to follow the procedure laid down in S. 65B of Indian Evidence Act, 1872-Admissible as evidence-Deposits in HSBC London-Income from other sources-Art. 23(3) of Indo-UK DTAA is not automatically applicable-DTAA-India-UK-Bank account showed closed status-Notional interest income cannot be estimated. [S. 90, Indian Evidence Act, 1872, S.65B, Art. 23(3)]

S. 151 : Reassessment-Sanction for issue of notice-Notice was issued before the expiry of four years from the end of the relevant assessment year-It should have been issued after obtaining the satisfaction of Jt. CIT-The approval obtained from the Principal CIT is not valid. [S. 147, 148, 151(ii)]

S. 147: Reassessment-Incorrect information-Reassessment is not valid-Receipt on sale of goods-Addition is deleted. [S. 68, 148]

S. 147: Reassessment-Cash deposits-No addition was made in respect of reasons recorded-Issue which is not subject of recorded reason-Addition cannot be made-Additional ground is admitted.[S. 148, 254(1)]

S. 147 : Reassessment-Survey-Information from Investigation Wing-Re assessment is valid-Expenses through international credit cards-Addition is sustained.[S.69C, 133A, 148]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment order is quashed. [S. 143(3)]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Re assessment is bad in law.[S. 45(2), 148]

S. 145A : Method of accounting in certain cases-Valuation of closing stock-Valuation of Inventories-If the AO add VAT to the closing stock value, then necessarily he has to add VAT amount in the opening stock value also and in that circumstances the net effect will be neutral-Addition of VAT amount to the closing stock value is not sustainable. [S.44AB]

S. 145 : Method of accounting-Rejection of books of account is justified-Bulk journal entries in the books of account-Provisions of S.40(a)(ia),40A(3) cannot be applied-Companies engaged in the same line of business, have reported profitability in the range of 3 per cent to 9 per cent across these years-The profit of the assessee is to be estimated at 10 per cent of the contractual receipts. [S. 40(a)(ia), 40A(3), 153A]

S. 143(3): Assessment-Limited scrutiny-Conversion of limited scrutiny into complete scrutiny without prior approval-CBDT Instruction No. 5 of 2016-Assessment is bad in law. [S. 143(2)]