S. 153C : Assessment-Income of any other person-Search-Limitation-Period to be reckoned from date of receipt of books of account, documents or seizure of assets by Jurisdictional Assessing Officer of non-searched person-Commissioner (Appeals) considering limitation period from date of search-Notice is barred by limitation.[S. 132, 132A]

S. 153B : Assessment-Search-Time limit-Limitation-Last panchanama-Subsequent panchnama revoking prohibitory order without seizure of material-Time limit is not extended-Restraint order not lifted within one month of assessment order-Central Board Of Direct Taxes instruction-Release of prohibitory order,panchnama and assessment order is invalid-Central Board Of Direct Taxes Circular, Dated 3-7-2002-Last panchnama cancellation of restraint order-Second Panchnama is not last panchnama of conclusion of search-Electronic documents used as evidence-Mandatory conditions of Section 65B of Indian Evidence Act is not complied with-Not admissible evidence-Bogus purchases-Cash purchase of tobacco from grey market-Estimation of profit at 12.5 Per Cent. is proper. [S. 132(3), 132(8A), 143(3) 153A, Indian Evidence Act, 1872, S.65B (2)(d), 65B(4)]

S. 153A : Assessment-Search-Additional ground admitted-Seized document related to third party-Proceedings to be transferred to Assessing Officer of third party-No satisfaction note prepared and no proceeding under Sectionb153C is initiated-Employee of searched company-Proceedings under section 153A is invalid. [S. 132, 153C]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation–Notice issued on 30-6-2021 will not relate back to original date where limitation expired on 31-3-2021-Notice is barred by limitation-Order and consequential notice is set aside-Information from Investigation wing-Accommodation entries-Charges are incorrect-Assessment made without application of mind-Notice and order is quashed. [S. 147, 148, 148A(b), 148A(d)]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Delay condoned-Additional ground-Earlier orders passed on basis of notice under Section 148 is not existing on date of notice-Assessment is invalid and quashed.[S. 147, 253(5), ITATR. 11]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Interest-Notice and proceedings initiated beyond prescribed time-limit-Barred by limitation. [S. 148, 148A(b), 148A(d), 149 (1)(b)]

S. 148 : Reassessment-Notice issued in the name of dead person-Reassessment is bad in law and quashed.[S. 147, 159(2)(b), 159(3)]

S. 147 : Reassessment-Change of opinion-Issue dealt in original assessment proceedings-Reassessment is quashed. [S.11, 12AA 148]

S. 147: Reassessment-After the expiry of four years-Information from investigation wing-Accommodation entry-Reassessment is invalid. [S. 133(6), 148]

S.147: Reassessment-After the expiry of four years-Investments-No failure to disclose material facts-Onus on revenue-Reassessment notice and order is quashed. [S. 143(3). 148]