S. 221 : Collection and recovery–Penalty-Tax in default-assessee filing return without payment of self-assessment tax-financial constraint and liquidity crunch faced by assessee at time of filing of return-good and sufficient reason for failure – Levy of penalty is held to be not justified.[S. 140A]

S. 201 : Deduction at source-Failure to deduct or pay–Airline-Not liable to deduct tax at source for passenger service fee collected by it from passengers and handed over to airport authorities and the amounts retained by banks from the passengers for booking tickets to fly in the aircrafts operated by the Assessee. [S.194H, 194J, 201(1), 201 (IA)]

S. 154 : Rectification of mistake–Expenditure incurred on issue of bonus shares–Allowable as revenue expenditure-Non-consideration of a decision of jurisdictional court or of the Supreme Court was a mistake apparent from the record and therefore liable to be rectified. [S. 35D, 37(1)]

S. 153A : Assessment–Search- Burden is on the department to prove that the seizure of the document and content thereof, so as to treat the document to be an incriminating document.-Deletion of addition is held to be justified. [S. 131]

S. 153A : Assessment–Search-Pending assessment abate–Order is set aside to determine the income as per S. 153A of the Act. [S.132, 143(2)]

S. 153A : Assessment–Search or requisition-Unaccounted sales- Seized documents containing both accounted as well as unaccounted sales-No material on record suggesting sales made over and above sales recorded in seized documents-Addition to be confined to income from unaccounted sales recorded in seized documents search and seizure.

S. 153A : Assessment-Search or requisition-income from undisclosed sources-excess stock-waste included by assessee in stock of yarn-department treating it as fresh yarn and making addition–Addition is held to be not valid.

S. 148 : Reassessment–Notice-reopening against assessee-firm on basis of order on appeal in case of partner of assessee-reassessment to bring to tax in hands of firm sum wrongly taxed in partner’s hands-limitation to be considered as on date of passing assessment order in partner’s hands. [S. 147, 149, 150(1)]

S. 147 : Reassessment-Order passed without disposing the objections–Order is bad in law. [S. 148]

S. 147: Reassessment-Assessment made in the name of a non-existing entity is void and liable to be quashed-Jurisdictional defect cannot be cured-Mere participation by the Assessee had no effect as there can be no estoppel against law. [S. 148, 292B R.27]