S. 147: Reassessment-After expiry of four years-Change of opinion-Interest income capitalized to Work-in-Progress and non-addition of provision for income-tax-Issues were subject-matter of query during original assessment-Reopening held to be based on mere change of opinion and hence invalid. [S. 4, 56, 143(3), 148, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Excess investment in shares-Where reasons for reopening were based entirely on financial statements already on record during the original assessment, it amounted to a mere change of opinion and was not sustainable as there was no failure on the part of the assessee to disclose material facts fully and truly. [S. 14A, 69, 148, Art. 226]

S. 147 : Reassessment-After expiry of four years-Change of opinion-Reopening on issue already examined during original assessment proceedings held to be invalid. [S. 69, 143(3), 148, Art. 226]

S. 143(3) : Assessment-Amalgamation-Order passed on non-existent amalgamating company; invalidity-Defect is jurisdictional and not curable under S. 292B,even if, the assessee has participated in the assessment proceedings. [S. 260A, 292B]

S. 139 : Return of income-Condonation of delay-One-day delay due to a bona fide technical glitch must be condoned; rejection of application on the ground that the return was already processed is misconceived. [S. 80P, 119(2)(b), 143(1), Art. 226]

S. 132B : Application of seized or requisitioned assets-Release of seized cash-Demonetisation-Specified Bank Notes (SBN)-Seizure by a Law Enforcement Agency covered by exception in SBN Act; RBI directed to accept SBNs seized by department prior to appointed day where assessee offered income to tax. [S. 131, 132, Specified Bank Notes (Cessation and Liabilities) Act, 2017, S. 5, Art. 226]

S. 127 : Power to transfer cases-Centralization for coordinated investigation-Transfer of NRI assessee’s case to another city upheld where he had transactions with persons whose cases were already centralized there; plea of breach of natural justice rejected due to lack of prejudice and assessee’s acquiescence. [S. 142(2A), 153A, Art. 226]

S. 115JB : Book profit-Consequential adjustment-Where the primary disallowance under section 14A is deleted, the consequential adjustment to book profit does not arise.[S. 14A]

S. 115BBC : Anonymous donations-Determination of tax in certain cases-Cash donations-Onus is on assessee under section 68 to substantiate genuineness of donors-Failure to discharge onus justifies treating donations as anonymous-Addition was justified. [S. 68, 133(6), 260A]

S. 92C : Transfer pricing-Arm’s length price-Corporate guarantee-Adjustment made without giving reasons is unsustainable-Order of Tribunal affirmed.[S. 260A]