S. 254(2A): Appellate Tribunal –Stay- Deposited 71 per cent of tax demand raised in reassessment proceedings- Tribunal is not justrified in rejecting the stay – Balance amount of tax and interest was to be stayed till disposal of assessee appeal. [ S.226, 254(1) ]

S. 147 : Reassessment – Legal represenntaive – Liability – Not inherited anything from his father- Huge deposits prior to death – Reassessment is held to be bad in law . [ S..144, 148 159, Art .226 ]

S.54F : Capital gains- Investment in a residential house – The assessee is entitled to the withdrawal of the amount deposited under Sub-Section (4) of Section 54F of the Act under the capital gain account subject to deduction of tax applicable to the case on hand. [ S.45, 54F(4) ]

S. 92C : Transfer pricing – Arm’s length price – Selection of comparables -Comparision with high brand value and higher scale of operations and profit margin to be excluded – Comparables have to be functionally similar but they should have similar business environment and risks as the tested party- Tribunal order is set aside .[ S.144C ]

S.147: Reassessment-After the expiry of four years- Asset written off and factory land development charges – No allegation of failure to disclose material facts- No new facts- Notice of reassessment is held to be invalid .[ S. 148 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Record – Pendency of appeal before CIT (A) -Order passed after considering all Details-Revision is held to be not valid .[ S. 40A(3), 250, 263 , Expln.1(c)]

S. 220 : Collection and recovery – Assessee deemed in default – Stay – Pendency of appeal before CIT(A) – Application for stay of recovery can be made before the CIT(A) to stay the demand still disposal of appeal by the CIT (A) [ S. 115Q, 220 (6) , 246A, 264 , Art .226 ]

S. 154 : Rectification of mistake – Pendency of appeal or revision is no bar on the AO on power of amendment or rectification -Matter did not assume character of a sub-judice matter . [ S.154(IA) , Art .226 ]

S. 220 : Collection and recovery – Assessee deemed in default – Stay – Relevant consideration – Conflicting decisions of Tribunal- Complete stay of demand may be granted -Decision of Jurisdictional High Court is binding on the CIT(A) – Stay was granted [ S. 220(6) , Art .226 ]

S.147: Reassessment – Change of opinion- Amortisation of barnd value – Query raised and responded – Issue examined in the original assessment proceedings – Reassessement is held to be bad in law [ S.115JB 148 , Art .226 ]