S. 263 : Commissioner-Revision of orders prejudicial to revenue-Transaction fee-Subject matter of appeal before CIT(A)-Original assessment reopened to tax profits earned on surrender of purchase pension policy-Return filed was accepted in reassessment proceedings-Reassessment becomes invalid-Revision is held to be not valid. [S. 14A, 56, 143(3), 147, 148]

S. 154 : Rectification of mistake-Deduction of tax at source-Aircraft lease-Order of High Courts-Tribunal for earlier year holding payment exempt and High Court dismissing Department’s appeal-Order of CIT(A) allowing the rectification order is held to be justified. [S. 10(15A), 40(a)(i), 250]

S. 153A : Assessment-Search or requisition-Addition made to the income of the assessee based on the documents viz. ‘loose sheets’ and ‘scraps of paper’ seized during a search conducted on a third party-Inadmissible evidence-Addition is not valid. [S. 132]

S. 148 : Reassessment-Notice-Dispatched by speed post within time but retuned by postal authorities-Notice never served-Reassessment proceedings in valid. [S. 147, 149]

S. 147 : Reassessment-Accommodation entries-Information from Investigation Wing-Borrowed satisfaction-Reassessment is not valid-Judicial discipline-CIT(A) is bound to follow the order of Jurisdictional Tribunal-Share capital-Letter of confirmation was filed-Addition as cash credits is not justified. [S. 68, 148, 254(1)]

S. 147 : Reassessment-Rectification proceedings initiated but not rectified-Reassessment proceedings initiated for same reasons-Held to be not valid. [S. 148, 154]

S. 147 : Reassessment-Business connection-No new tangible material-Reassessment is bad in law. [S. 9(1)(i), 148]

S. 147 : Reassessment-After the expiry of four years-Search and Seizure-General information from Investigation wing-No failure to disclose material facts-Re assessment not valid. [S. 148]

S. 145 : Method of accounting-Estimation of income in an arbitrary, capricious, and wild manner is not permitted in the eyes of the law and must be on a reasonable basis in congruent to the result of the prior previous years. [S. 145(3)]

S. 145 : Method of accounting-Disputed amount-The tax paid in subsequent year-Double taxation-Same income cannot be taxed twice. [S. 4,5]