Section 271(1) of the Income Tax Act

Additions to income based on statements recorded without providing the assessee an opportunity to cross-examine the declarants are unsustainable due to a violation of natural justice principles.

To disallow long-term capital gains, the Assessing Officer must rely on cogent proof, not mere suspicion or presumption, regarding share price manipulation or the nature of the companies involved.

When an assessment order is erroneous and prejudicial to the revenue, the Commissioner has the jurisdiction under Section 263 to revise it, which can include directing a fresh assessment that encompasses the assessment of penalties.