S. 271(1)(c) : Penalty – Concealment – Addition set aside Levy of penalty is held to be not valid – Not specifying the charge – Levy of penalty is not valid – Penalty on account of deemed concealment is unsustainable as the Assessing Officer has not made any reference to any incriminating material or income declared by the assesssee [ S. 132(4) , 153A, Explanation 5, 274 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue -Limitation -Reassessment – Issue subject of revision pertaining to original assessment – Original assessment passed on 16-1 2014 – Revision order on 26- 2 -2019 – Revision is barred by limitation , revision could have been taken up to 31 -3 -2016 [ S. 80IA ,80IB 143(3), 147 , 148, 263(2) ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Accommodation entry -Principal Commissioner not agreeing with manner of enquiry conducted by Assessing Officer — PCIT cannot substitute his own reasons- Revision is held to be not valid [ S.143(3) ]

S. 254(1) : Appellate Tribunal – Duties- Remand proceedings – Claim accepted by the Assessing Officer – Deletion of addition by the CIT (A) is held to be justified [ S.250, 253 ]

S. 246A : Appeal – Commissioner (Appeals) – Appealable orders – Revision – When appeal was pending revision application was filed – Revision is held to be not valid – Cost of Rs 40000 was imposed upon assessee- CIT(A) is directed to decide the matter on merits [ S. 249, 264 ]

S. 244A : Refund – Interest on refunds -Intimation — Assessable in year granted — If interest adjusted with prior tax liability of earlier years and paid to Government account — No need of separate intimation.

S.234E: Fee-Default in furnishing the statements- Deduction of tax at source —Amendment enabling levy of late fee for default in furnishing statement brought in with effect from 1-6-2015 — Prospective in nature — Levy of late fees while processing statement of tax deducted at source before amendment — Not sustainable.[ S.200A ]

S.147: Reassessment —Wrong facts and figures- Non-application of mind —Reassessment is held to be not valid [ S. 68, 148 ]

S.147: Reassessment-After the expiry of four years- Cash credits – All material facts were disclosed in the original assessment proceedings -Reassessment is held to be not valid [ S.68 , 148, 194A ]

S. 145 : Method of accounting – Fall in net profit rate -No specific defects pointed out in the books of account – Remand report – Addition of higher rate of profit is held to be not justified .