S. 282: Service of notice-Income tax Appellate Tribunal-Speed post-Registered post-Envelope containing notice under section 148 was not returned back-Service of notice through personal service as specified by Order V rule 17 of CPC and Part II of section 282(i) was not validly made-The service of notice through the Income Tax Inspector was also not made upon the appellant by affixing the same on the address of the assessee in absence of personal service upon the assessee-Order passed by Tribunal is set aside-Interpretation of statutes: Rule of strict interpretation.[S. 142(1), 144, 147, 148, 254(1), 260A, Code of Civil Procedure, 1908, Order V rule 17 of Code of Civil Procedure, Indian Post Office Act, 1898, the Post Office Act, 2023, the Indian Post Office Rules, 1933, the Post Office Rules, 2024, R. 2(1)(k), 58, 60, 62, General Clauses Act, 1897, S. 27, Indian Evidence Act 1872, S.114(f)]

S. 281B: Provisional attachment-Provisional attachment order dated 1-6-2017 was valid for a period of six months as per section 281B(2) until 1-12-2017, and in the absence of any extension, the order ceased to have effect thereafter. [Art. 226]

S. 279: Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-First offence-3 per cent compounding charges were leviable upon the petitioner and not 5 per cent. [S.279(2), Art. 226]

S. 276B : Offences and prosecutions-Failure to pay to the credit tax deducted at source-Sentence of fine as imposed by ACMM was to be modified, and the company was sentenced to admonition. [S.278AA, 278B, Code of Criminal Procedure, 1973, S. 378]

S. 276 : Offences and prosecutions-Removal-Concealment-Transfer-Delivery-Property-Thwart recovery-Transfer of Car to daughter-in-law of director-Company was not made as accused-[S.278B, 281, Art. 226]

S. 270A:Penalty for under-reporting and misreporting of income-Matter remanded to the Assessing Officer to provide an opportunity of hearing and pass a speaking order. [S.92CD(3) Art. 226 ]

S. 268A: Appeal-Instructions-Monetary limits prescribed in CBDT Circulars would apply to pending appeals-Exceptions carved out by CBDT Circulars would apply only prospectively-Appeal of revenue dismissed.[S. 260A]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Cash credits-Share premium-Capital transaction-Second time on ground of inadequate enquiry-Tribunal, on examining the factual position and also noting the legal position, had granted relief to assessee-No question of law arose from order of Tribunal.[S.68, 143(3), 260A]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Capital gains-Land used for agricultural purposes-High Court affirmed the quashing of the revision order by the Tribunal-SLP of revenue is dismissed as the revenue could not explain the delay of 305 days in filing the SLP. [S. 54B, Art. 136]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record-Industrial undertakings-Infrastructure development-Contractor-Developer-Tribunal had not considered evidence on record and had merely recorded bare conclusions without setting out any reasons in support thereof, order of Tribunal under section 254(1) of the Act was set aside and matter was remitted back to Tribunal for disposal afresh on merits. [S.80IA(4)(1)(b),254(1), Art. 226]