S. 244A: Refunds-Interest on refunds-Order giving effect-Revenue was to be directed to pay interest or compensation at 6 per cent per annum on delayed payment of interest of Rs. 7.58 crores from 01-08-2023 till the date of payment of such interest. [S.244(IA) Art. 226]

S. 222: Collection and recovery-Certificate to Tax Recovery Officer-Order of Tribunal attained finality-Tax demand was paid-Tax recovery officer was directed to lift the attachment.[S. 153A, 254(1), Art. 226]

S. 158BC: Block assessment-Undisclosed income-Incriminating material-Search-Retracted statement-No evidentiary value-Order of block assessment was quashed and set aside.[S. 132, 132 (4), 158B, 260]

S. 153D: Assessment-Search and seizure-Approval-Single approval-Without reference to seized material or assessment records, such approval was invalid. [S.153A, 260A]

S. 153C : Assessment-Income of any other person-Search-Opportunity of cross-examination-Assessment founded on diaries and statement under section 132(4) of a third party-Cross-examination denied by the Assessing Officer and the Tribunal-Violation of natural justice-Matters remanded for fresh adjudication after allowing cross-examination. [S. 132(4), 143(3), 153A, 260A]

S. 153C: Assessment-Search-Other person-Date of initiation of search-Date of handing over seized material-Since initiation of search was subsequent to 1-4-2021, provisions of section 153C would not apply and thus, impugned notice issued under section 153C was to be quashed-Notice invalid. [S.132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Assessing Officer of searched party and third party was the same-Time limit of clause (ii) of third proviso to section 153B(1) shall apply which was 12 months from end of financial year in which search took place-Order was quashed. [S. 153B, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction was recorded four years after search and two years after assessment of searched person-Notice was quashed and set aside. [S.132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Loose sheets-Satisfaction note-A sheet of paper containing typed entries and in loose form, not shown to form part of books of account regularly maintained by assessee-Satisfaction note is required to be recorded under section 153C for each assessment year and where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings-Power to transfer cases-No reasonable opportunity had been provided before transferring case and officer of Bangalore had sent Notice and Assessment order to assessee who was a resident of Delhi, it was in total violation of section 127-Order of High Court affirmed-SLP of revenue dismissed. [S. 127, 132, Art. 136]

S. 153A: Assessment-Search or requisition-No incriminating material-Order of Tribunal deleting the addition was affirmed-No substantial question of law. [S. 132, 260A]