S. 153A : Assessment – HSBC Bank Geneva-No addition can be made without any incriminating documents seized in the Course of Search-When the information is not provided by Swiss Competent Authority- No addition can be made as undisclosed asset in Swiss Account- Addition was deleted-Penalty was quashed-DTAA-India-France. [S.90, 132(4), 153B(1)(a), Art.26]S. 153A : Assessment – HSBC Bank Geneva-No addition can be made without any incriminating documents seized in the Course of Search-When the information is not provided by Swiss Competent Authority- No addition can be made as undisclosed asset in Swiss Account- Addition was deleted-Penalty was quashed-DTAA-India-France. [S.90, 132(4), 153B(1)(a), Art.26]

S. 144B : Faceless Assessment – Assessment order was passed without issuing show cause notice or draft assessment order -Violation of principle of natural justice – Alternative remedy is not bar – Operation of assessment order was stayed [S.143 (3), Art , 226 ]

S.144B: Faceless Assessment – Variation in income – Request made to personal hearing was not complied with – System has to be transparent and person administering it have to be accountable- Order was set aside . [ S.142 (1) , Art , 226 ]

S. 143 (3)): Assessment – Faceless assessment – Natural Justice – Order passed during lockdown – Non compliance of notice – High Court by passing interim order stayed the assessment order. [ S. 144 , Art . 226 ]

S. 271D : Penalty-Takes or accepts any loan or deposit-Ignorance of provisions or lack of banking facilities in area-Not accepted as reasonable cause when the assessee doing large scale finance business dealing with public. [S. 269SS, 273B]

S. 271(1)(c) : Penalty-Concealment-Finding in assessment proceedings-Burden of proof-Gift held to be nongenuine-In penalty proceedings revenue authorities have to arrive at independent finding related to concealment of income or inaccurate particular. [S. 68]

S. 254(2A) : Appellate Tribunal-Powers-Stay-Capital gains-Denial of exemption-Deposited a sum of Rs. 15.71 lakhs out of demand of Rs. 61.99 lakhs, and directed to deposit a further sum of Rs.15 lakhs and on such deposit there shall be an order of interim stay till disposal of appeal before Tribunal. [S. 10(38), 45, 254(1), Art. 226]

S. 250 : Appeal-Commissioner (Appeals)-Dismissal of appeal on the ground of defective appeal-Rejection of stay application-Directed to file additional memorandum of appeal and stay application. [S. 220(6), 271B, Art. 226]

S. 237 : Refund-Delay in processing refund-Duties of tax Authorities-Directed to process return of income as expeditiously as possible and pay refund to assessee if any due. [S. 143(1), Art. 226]