S. 154 : Rectification of mistake-Adjustment of current year loss-Income declared u/s. 158D of the Act-Debatable issue cannot be rectified. [S. 158BD]

S. 154 : Rectification of mistake-Surrendered income-Survey-Business income-Increasing the rate of tax from 30 percent to 60 percent and levying surcharge and cess on undisclosed income is held to be not valid. [S. 68, 69, 69A, 69B, 69C, 69D, 115BBE, 131, 133A]

S. 153D : Assessment-Search-Approval-Non applicability of mind by the Addl. CIT-Approval was granted without application of mind-Order was quashed. [S. 153A]

S. 153D : Assessment-Search-Approval-Prior approval cannot be granted over the phone-Approval on fax/ email can be considered approval in law if it fulfils other requirements of law-Order passed before receiving the approval-Order is null and void. [S. 153A]

S. 153C : Assessment-Income of any other person-Search-No incriminating material was found during search-Statement of third party not sufficient to fasten any liability upon-Addition is deleted. [S. 131, 132]

S. 153C : Assessment-Income of any other person-Search-Assessments for 2006-07 and 2007-08 beyond purview of assessment-Amendment with effect from 1-4-2017 that block period for other person would be same six assessment years-prospective-Satisfaction note-Must justify that document found during search does not belong to person in respect of whom search conducted and clearly display reasons based for satisfaction that seized documents belong to another person-Satisfaction of higher forum, Settlement Commission, would prevail over opinion of Assessing Officer-Pen drive seized during search-Addition made on protective basis in hands of assessee on basis of Satisfaction Note that pen drive belonged to assessee-Satisfaction of Assessing Officer of person in respect of whom search conducted defective and not sustainable in law-Order of Settlement Commission gives protection only to applicants before Settlement Commission-Substantive additions deleted-Protective additions cannot survive except in case of finding that income belongs to person in whose hands protective additions are made. [S. 132, 153A, 245D, 245I]

S. 153C : Assessment-Income of any other person-Search-Documents found in the premises of third party-Addition on the basis of such documents are held to be not valid [S. 132(4A), 292C]

S. 153C : Assessment-Income of any other person-Search-Search on 13th March, 2015-Documents prior to Ist June, 2015-Not belongs to the assessee-Allegation of information belongs to assessee-All assessment orders are quashed-Assessment u/s 153A can be made only on the basis of material found during the course of search carried out against the assesee-Assessment-Limitation-Time limit for passing order on 31st March, 2017-Order passed in December 2017 is held to be barred by limitation-Reassessment-Materials discovered during search proceedings for period beyond six preceding assessment years can be used for invoking the provisions of section 147 of the Act-Recorded reasons do not match with actual addition-No addition can be made in the reassessment proceedings-Addition cannot be made-Interest free loans given to partners-Not mandatory to charge interest-Addition cannot be made on notional basis. [S. 5, 132, 132(3), 147, 148, 153A, 153B]

S. 153C : Assessment-Income of any other person-Search-No incriminating materials-Addition is not justified-Obsolete provision written off-Allowable as deduction-Provision for liquidated damages-Allowable as deduction. [S. 37(1), 143(3)]

S. 153A : Assessment-Search or requisition-Unabated assessment No material relating to addition found in search-Addition not sustainable. [S. 132, 143(3)]