Section 120(4)(b) of the Income Tax Act

When no specific statutory period of limitation exists, proceedings under Section 201(1) and 201(1A) of the Income-tax Act, particularly for payments to non-residents, must be initiated within a reasonable period of four years. This limitation also applies to consequential penalty proceedings under Section 271C.

When the valuation of closing stock is adjusted to include CENVAT or Modvat credit under Section 145A, a corresponding adjustment must also be made to the opening stock.

When the Assessing Officer revalues the closing stock, the opening stock must also be revalued on the same basis to ensure consistency in the method of accounting and proper computation of business income.

The computation of deduction under Section 80HHC requires applying the formula: Profits derived from exports = (Profits of the business x Export Turnover) / Total Turnover. For this calculation, miscellaneous income, sundry sales, and income from services, if not directly relatable to export activity, are generally to be excluded from "profits of the business" and "total turnover".

Payments made by an assessee to release property from an encumbrance or settle disputes, which are essential for a sale transaction to materialize, are allowable as a deduction under Section 48 of the Income-tax Act for computing capital gains. Such expenditure either reduces the full value of consideration or is deductible from it.

If an assessee fails to raise an objection regarding the jurisdiction of the Assessing Officer within the stipulated time, they will be barred from raising the issue later. If the Commissioner decides the issue, their decision is final and cannot be questioned in appeal.

A credit amount outstanding for several years cannot be treated as a remission or cessation of a trading liability under Section 41(1) merely because the assessee could not prove the genuineness of the transaction or because the liability is barred by limitation.

The Assessing Officer can determine the annual value of a property based on what it might reasonably be let for from year to year or its annual ratable value, especially when rent is not charged or is below market rates. This approach is permissible under Section 23(1)(a) of the Income-tax Act.

A loan or advance received by an assessee cannot be treated as such for the relevant previous year if it was not advanced by the lender during that year, even if there was an opening credit balance.

Income-tax authorities are of co-ordinate jurisdiction, and the Act does not prescribe their respective jurisdictions or functions, leaving it to be decided by the Board or Commissioner. Allocation of jurisdiction is for administrative convenience and does not invalidate actions due to defects in its exercise.