S. 147 : Reassessment-With in four years-Interest paid on loans borrowed-Controlling interest-Change of opinion-Allowed as business expenditure-Notice to reopen assessment was merely on basis of change of opinion of Assessing Officer and same was to be set aside. [S. 37(1), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Sale of shares-Tax Residency Certificate under laws of Mauritius-Capital gains-Nothing in form of information or material had been put on record-Reassessment notice is quashed and set aside-Matter was to be remanded back to AO to confront assessee with relevant material-DTAA-India-Mauritius. [S. 148, Art. 13, Art. 226]

S. 147 : After the expiry of four years-Investment in Mutual funds-Did not file the income tax return-Did not respond to various notices-Neither conduct nor alleged prejudice suffered by assessee prompt Court to exercise any discretion to receive matter and adjudicate same without leaving assessee free to approach regular statutory remedy in accordance with law-Writ petition is dismissed. [S. 10(26),10(45), 139(1), 139(4C), 142(1), 148, Art. 226, Civil Procedure Code, 1908, Order VII Rule 11,]

S. 147 : Reassessment-After the expiry of four years-Order passed without disposing off objection raised by passing a speaking order-Assessment order and notice is set aside. [S. 143(3), 148, Art. 226]

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]