S. 153 : Assessment-Reassessment-Limitation-Non-resident-The assessment was made as per the procedure laid down in S. 144C-No reference was made under S. 92CA(1)-Time-limit for completing the assessment under S. 147 was available upto 31st March, 2022-The final assessment order passed by the AO under s. 144 r/w s. 144C, dt. 12th Jan., 2023-Barred by limitation. [S.92CA, 144, 144C,147, 148 153(2)]

S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Neither reference to the date of search nor description of the nature of documents seized-Assessment order is invalid-No incriminating material was found-Addition is deleted. [S. 132]

S. 151 : Reassessment-Sanction for issue of notice-More than three years from the relevant assessment year-Sanction for the order under s. 148A(d) was obtained from Principal CIT and not Principal Chief CIT-Reassessment proceedings are quashed [S. 147 148, 148A(b), 148A(d)]

S. 147 : Reassessment-Cash deposits-Search-Salary-Investigation-Reassessment is valid-Unexplained cash-Source is not explained-Addition is affirmed. [S.68,69A, 132, 148]

S. 147: Reassessment-Cash deposit-No mentioning of name of asseessee in Investigation report-Objection not fully disposed of-Reassessment is quashed. [S.68,133(6), 148]

S. 147 : Reassessment-Non application of mind-Shell companies-Web site of the Income-tax portal-Re produced information without cross verification-The reopening of assessment is quashed.[S. 148]

S. 145 : Method of accounting-Failure to produce details-Rejection of books of account is justified-Matter is restored back to the AO to estimate the profit of the assessee at a percentage worked out on the basis of preceding three years. [S. 145(3)]

S. 143(3): Assessment-Limited scrutiny-Interest income mismatch-Without following the prescribed procedure and necessary approval of the competent authority conducting an enquiry on the issue which is outside the limited scrutiny would be beyond the jurisdiction of the AO-The Assessment order is quashed. [S. 143(2)]

S. 143(3): Assessment-Jurisdiction-Income include loss-Corporate assessee-Jurisdiction was with ACIT/Dy. CIT-The assessee had disclosed loss of Rs. 3,29,55,888-Notice is valid-Rejection of books of account is justified-Estimate of 10 percent of net profit is reasonable. [S. 2(24), 120, 143(2), 145(2)]

S. 143(2) : Assessment-Notice-Shifting of residence from Delhi to Gurgaon-Change is reflected in the return filed-Notice issued by the Assessing Officer from Delhi is without jurisdiction-Quashed-Additional ground-Jurisdictional issue-Admitted [S. 254(1)]