S. 153C : Assessment-Income of any other person-Search-Appelllate Tribunal-Additional ground-Legal issue-Admitted-The assessment ought to have been made u/s. 153A of the Income-tax Act, 1961 and not u/s. 143(3) of the Act and therefore, the assessment made by the Assessing Officer was bad in law and invalid.[S. 143(3), 153A, 254(1)]

S. 153C : Assessment-Income of any other person-Search-In case of concluded assessment, addition can only be made on the basis of an incriminating material .[S. 132,143(3)]

S. 153A : Assessment-Search-No addition can be made in case of completed or abated assessments in absence of incriminating material .[S. 68,132]

S. 153A : Assessment-Search-Cash Credits-No incriminating material found during search-Unabated assessment-Additions not sustainable. [S.68]

S. 151 : Reassessment-Sanction for issue of notice-Sanction of CIT instead of A/JCIT-Notice is bad in law. [S.147 148, 151(2)]

S. 148 : Reassessment-Notice —Information from other ITO-Income from undisclosed sources-Bogus purchases-Assessing Officer not pointing out any defect in maintenance of books of account-Reassessment notice is not valid .[S. 147]

S. 148 : Reassessment-Notice-Reassessment proceedings taken prior to expiry of assessment year void ab initio.[S. 139(1), 139(4), 142(1)]

S. 148 : Reassessment-Notice-Dissolution of Company-Name of the company had been struck off from Register of Companies-Not intimidated to Assessing Officer-Notice is valid-Sanction-Reassessment for the assessmentyear 2003-04 is quashed as the Commissioner had granted approval instead of the Additional Commissioner or Joint Commissioner as prescribed under the law-Quantum of addition-Matter remanded. [S. 69, 147,151]

S. 147: Reassessment-International transaction-Case transferred to transfer pricing officer-Verification of records-Held, reopening of assessment bad in law. [S. 143(3),148]

S. 147 : Reassessment-Change of opinion-Original assessment made on scrutiny-no tangible material coming into possession of AO for formation of belief that income had escaped assessment, Reassessment on materials is impermissible. [S. 143(3), 148]