S. 153D: Assessment-Search-Approval-Mechanical approval-Multiple approval on other group cases -Non-application of mind -Order was quashed. [S. 132, 153A]

S. 153C: Assessment-Income of any other person-Search-Undisclosed contract receipts -Estimation of profit at 8% upheld-Addition was deleted. [S. 44AD, 132(1)]

S. 153C: Assessment of person other than searched person -Satisfaction note -Addition on basis of unacted seized agreement -Invalid approval under section 153D -Entire assessment quashed. [S. 69C, 132, 143(3), 153D]

S. 153C: Assessment-Income of any other person -Search-A satisfaction note is required to be recorded under section 153C for each assessment year-A consolidated satisfaction note recorded for different assessment years would vitiate entire assessment proceedings [S. 132, 153A]

S. 147: Reassessment -“Reason to believe” -Reopening invalid where reasons recorded are factually incorrect and based on non-application of mind-Assessment was quashed. [S. 148, 151]

S. 147: Reassessment -Addition cannot be made on issues unconnected with reasons recorded for reopening. Addition was deleted. [S. 148]

S. 147: Reassessment -Additional ground-Reassessment proceedings initiated solely on the basis of NMS, without any independent verification, tangible material, or proper satisfaction recorded by the AO, would not confer valid jurisdiction under section 147-Initiation of reassessment proceedings under section 147 was void ab initio. [S. 115A, 139, 148, 194LD, 254(1)]

S. 147: Reassessment-Validity of addition on new issue -Assessment reopened for escapement of salary income, but addition made on account of Recurring Deposit Investment -Addition was deleted. [S. 148]

S. 145 : Method of accounting-Revenue recognition -Derecognition of income in books -Addition sustainable. [S.28(i)]

S. 144C: Reference to dispute resolution panel Reassessment -Limitation -Non-resident-Extended limitation under S. 153(4) available only where reference is made to Transfer Pricing Officer -Reassessment beyond prescribed period invalid. (S. 92CA, 144C, 148, 153(2), 153(4)