S. 271(1)(c) : Penalty – Concealment – Constitutional validity -Provision cannot be regarded as ultra vires of Constitution – Convention for Avoidance of Double Taxation between Union of India and other Sovereign Countries – DTAA -India – Japan .[S.90 , Art. 23, Art .226 ]

S. 268A : Appeal – Monetary limit- Audit objection- Reassessment – Assessment which was reopened on basis of audit objection- Revenue’s appeal would be covered by exception mentioned in Circular No. 3/2018 dated 11-7-2018 ( 2018) 405 ITR 29 (St) – Dismissal of appeal on ground of low tax effect is held to be not justified . [ S. 40A(3) , 148 ,254(1) ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Rejection of books of account and estimate of net profit – Estimate was reduced by CIT(A) and Tribunal- Revision order to verify unsecured loans and creditors -Issue which was not subject matter of appeal can be revised by the Commissioner- Revision order is held to be justified .[ S.69A , 145, 263 ( c )]

S. 254(2A): Appellate Tribunal –Stay- Power- Tribunal has the power to modify the stay order – Dismissal of stay application is held to be not justified on the ground that the Tribunal has no power to modify the stay order as the order is not passed u/s 254(1)- On facts only a part of interest amount is still remain unpaid rejection of application is held to be not justified . [ S.254(1), 254(2) ]

S. 148 : Reassessment – Notice – Notice issued in name of a dead person is not valid and liable to be quashed .[ S.147 , 159 ]

S. 69A : Unexplained money – Cash found – Residential premises of father-in-law- Addition cannot be made in the assessment of the assessee. [ S. 132, 132(4A, 153C, 292C ]

S. 37(1) : Business expenditure – Capital or revenue – Lease premises – Interior decoration – Capital expenditure – Depreciation is allowable. [ S.32 ]

S. 10 (23C): Educational institution- charitable trust – Entitle to exemption .[ S.2(15) ,10(23C)(iv) , 12AA ]

S. 279 : Offences and prosecutions–Sanction-Chief Commissioner –Wilful attempt to evade tax–Non-technical offence–False statement in verification- Reduction of penalty by CIT (A)-Prosecution cannot proceed–Compounding of offences-Application for compounding to be considered by committee specified in circular–DGIT has no jurisdiction to reject the application. [S. 119, 120, 276C(1), 273B, 277, 279(IA), 279(2), Art.141]

S. 271(1)(c) : Penalty–Concealment–Notice–Not specifying the charge – Defects could be rectified–Notice is not invalid–Writ to quash the notice is held to be not maintainable. [S. 292B, Art.226]