Interpretation of Taxing Statutes — Ejusdem Generis — Noscitur A Sociis.

S. 147 : Reassessment-After the expiry of four years-Unexplained expenditure-Search-No failure to disclose material facts-[S. 132, 143(3), 148]

S. 147 : Reassessment-After the expiry of four years-Unexplained investments-Sale of land-Depreciable assets-Information from investigation wing-Sale consideration n was disclosed in the return-Reassessment notice and order disposing the objection was quashed. [S. 48, 50C, 69A, 143(1), 148, Art.226]

S. 147 : Reassessment-After the expiry of four years-Cash credits-Search-Deposit of cash in bank-No scrutiny assessment was done-Reassessment notice is held to be justified.[S. 68, 143(1), 147, Art. 226]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose true and full material-Question was raised and reply was filed-Reassessment notice and order disposing the objection was quashed. [S. 14A, 142(1), 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Amalgamation-Carry forward and set off of accumulated loss and unabsorbed depreciation-No failure to disclose any material fact-Change of opinion-Reassessment notice and order disposing the objection was quashed. [S. 72A(2), 72(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Infrastructure development-Change of opinion-Pendency of appeal before CIT(A)-No failure to disclose material facts-Reassessment notice and order disposing the objection was quashed.[S. 80IA, 148,246A, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Share capital-Share premium-No failure to disclose material facts-Reasons not specifying material facts which are not disclosed-Notice and order disposing the objection was quashed and set aside. [S. 68, 132, 147, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Business expenditure-Penalty imposed for breach of a civil obligation would be outside purview of Explanation 1 to section 37(1)-Assessing Officer who had specifically gone into the allowability of the claim-A mere assertion in the absence of any material would not constitute a ‘tangible material’ for purposes of reopening an assessment-Reassessment notice and order disposing the objection was quashed. [S. 37(1), 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-CSR expenditure-Prior period gain /loss-No failure to disclose material facts-Provision of Explanation 2 to section 37(1) inserted with effect from 1st April 2015 operates prospectively, from assessment year 2015-16-Reassessent notice and order disposing the objection was quashed. [S. 37 (1), 148 Art, 226, Companies Act, 2013, S. 135]