S. 151 : Reassessment-Sanction for issue of notice-two separate notices-Same assessment year-No application of mind-Reassessment was quashed. [S. 147, 148]

S. 148 : Reassessment-Notice-Service of notice by affixture-Service of notice on consultant-Participated in the proceedings-Objection was raised for the first time before ITAT-For the limited purposes to verify the factual position as to whether the objections raised by the assessee through the letters referred or not, the ITAT restored the matter to the file of the AO for the limitation purpose of making necessary verifications. [S. 147, 254(1), 282, 292BB, Code of Civil Procedure, 1908, Order V-Rule 17 and Rule 19]

S. 148 : Reassessment-Two notice-Same assessment year-Issue of second notice during pendency of earlier reassessment-Second notice invalid-Reassessment invalid. [S. 147, 151]

S. 147 : Reassessment-Capital gains-Full value of consideration-Stamp valuation-Agreement to sale-Registration-No failure to disclose material facts-Capital gains offered in the Assessment year 2004-05-Reassessment is not valid. [S. 47, 45, 48, 148, Transfer of Property Act 1882, S. 53A]

S. 147 : Reassessment-After the expiry of four years-Share premium-Information obtained during subsequent year assessment proceedings-No tangible material-No reopening on suspicion-Reassessment not valid. [S. 68, 148, 151]

S. 147 : Reassessment-After the expiry of four years-details of inter-unit transfer provided during assessment proceedings-Full and true disclosure-No tangible material-Reopening invalid. [S. 10AA, 148]

S. 145 : Method of accounting-Rejection of Profit-No defects in the books of accounts-Similar profit margin in earlier years-Rejection of books of account is not justified-Estimation of net profit was deleted. [S. 145(3)]

S. 143(3) : Assessment-Non existing company-amalgamation-The assessment order having been passed in the name of a non existent entity, it is invalid and quashed-Being jurisdictional error, not protected u/s. 292B of the Act. [S. 92CA(3), 144C, 292B]

S. 143(3) : Assessment-Addition can only be made in respect of profits / income derived and not the entire turnover. [S. 263]

S. 132(4) : Search and seizure-Statement on oath-Merely on the basis of surrender when no corroborative evidence found against the assessee-Addition is not valid. [S. 132]