S. 153A : Assessment-Search or requisition-No incriminating material was found-Assessment not sustainable-Sales tax subsidy-Capital receipts-Not to be reduced from Book profits. [S. 4, 115JB, 132]

S. 153A : Assessment-Search or requisition-No notice u/s. 143(2) was issued after filing of return-Assessment was not invalid-Commissioner being supervisory authority, can issue administrative direction to Assessing Officer-Un explained investment-Addition can be made only in the year in which the investment was made-Assessing Officer cannot make the addition in the year of his choice-Swiss Bank-Base sheet-Authenticity of information not established-Addition as unexplained investment and addition on deposit is held to be not sustainable-Completed assessment-No addition can be made in the absence of incriminating material found in the course of search-Merely on the basis of statement u/s 132(4), addition cannot be made-Marriage expenses-Withdrawal from bank-Deletion of addition is held to be justified. [S. 69, 132, 143(2), 153D]

S. 147 : Reassessment-Accommodation entries-Reasons supplied was not the same reason recorded-Reopening of assessment was held to be not sustainable. [S. 148]

S. 147 : Reassessment-Survey-Inspectors report was not shown-Cross examination of witness was not provided-Reassessment was quashed. [S. 68, 148]

S. 143(3) : Assessment-Amalgamation of Banks by Gazette Notification-Assessment in the name of amalgamated or merged Entity-Assessment in the name of non-existent entities is held to be not sustainable.

S. 143(3) : Assessment-Income from undisclosed sources-Survey-Discrepancy of stock-Addition can be made only to the extent of profit element in sales considering the average sale price as ascertainable from sales recorded and not entire sale proceeds. [S. 133A]

S. 143(3) : Assessment-Bogus purchases-Grey market-Affidavit before Sales tax department-Only profit element can be estimated. [S. 133(6)]

S. 142(2A) : Inquiry before assessment-Special audit-Writ petition was pending-No stay of proceedings-Assessment completed beyond statutorily prescribed period-Barred by limitation. [S. 153A, 153B

S. 92C : Transfer pricing-Arm’s length price-Advertisement and publicity expenses-Margin earned higher than the third party transactions-Adjustment made was deleted.

S. 92C : Transfer pricing-Arm’s length price-Consultancy services-Matter remanded.