S. 263 : Commissioner-Revision of orders prejudicial to revenue-Agricultural income-Coffee curing-Specific queries during original assessment proceedings-Rule 7B deeming part of income as business income-Revision order was quashed. [S. 2(IA) 28(1),143(3), R.7B]

S. 263: Commissioner-Revision of orders prejudicial to revenue-
Cost of improvement-Limited scrutiny-Allowed claim towards cost of improvement under section 48 without conducting an inquiry or verification-Revision order affirmed. [S. 48, 54B]

S. 249: Appeal-Commissioner (Appeals)-Form of appeal and limitation-Delay of 1386 days-Ex parte assessment-Non-receipt of notices as they were issued to the jail Superintendent while assessee’s father was in jail-Delay was condoned, and the matter was restored to the file of CIT(A) for decision on merits.[S. 144]

S. 199 : Deduction at source-Credit for tax deducted-TDS was not allowed by the Assessing Officer/CPC due to an error in writing the wrong alphabet in PAN-The matter was remitted back to the Assessing Officer for fresh consideration.[S. 154]

S. 194A: Deduction at source-Interest other than interest on securities-Acquisition of loan-Purchased loans (including NCDs, ICDs and term loans)-No part of consideration paid by assessee could be termed as ‘interest’ paid by assessee to transferors-No obligation to deduct tax at source under section 194A. [S. 2(28, 133B(2), 201(1), 201(IA)]

S. 151: Reassessment-Sanction for issue of notice –Notice beyond a period of three years-Assessing Officer was statutorily obligated to have obtained approval from either of the authorities specified under section 151(ii) as per section 151 as amended by Finance Act, 2021, effective from 1-4-2021-Reassessment notice and consequential orders were quashed.[S.68, 148, 147,151 (ii)]

S. 151: Reassessment-Sanction for issue of notice –Notice under section 148 was issued after expiry of three years from the end of the relevant assessment year without approval from the authority prescribed under section 151(ii)-Reassessment proceedings were invalid. [S. 148, 151(ii)]

S. 149: Reassessment-Time limit for notice-Cash deposits-Notice under section 148A in July 2022-Revised notice period for assessment year 2013-14 expired on 26 June 2022-Notice issued on 25 th July 2022 was barred by limitation.[S. 69A, 147, 148, 148A(b), 148A(d)]

S. 147: Reassessment-Purchase of agricultural land-MOU on 21-3-2016-Presented before Joint Sub-Registrar on 24-3-2016, falling in financial year 2015-16 relevant to assessment year 2016-17-Reassessment for the assessment year 2017-18 was not valid. [S. 148 ITATR.27, Registration Act, 1908, S. 47]

S. 147: Reassessment-Unexplained investments-No addition was made on the reasons recorded-Reassessment order was quashed and set aside.[S.50C, 69, 148]