S. 234B : Interest-Advance tax–Levy of interest is held to be justified-Except on income which arose from retrospective operation of any statute, decision, etc., because in those type of cases, assessee was unable to know and assess his income and pay advance tax.[S. 234C]
S. 220 : Collection and recovery-Assessee deemed in default- Stay-Recovered 38% of disputed tax amount-No special circumstances pointed out to permit revenue to carry out full recoveries–Pending disposal of appeal further recovery proceedings were stayed.
S. 220 : Collection and recovery-Assessee deemed in default– Stay–Recovery of demand is stayed on deposit of 20% of outstanding demand–Advance tax paid and tax deducted at source while filing the return should also be considered.
S. 153C : Assessment-Income of any other person-Search-Pendency of writ petition the AO passed the assessment order-Directed to file an appeal and all contentions are left open. [Art. 226]
S. 153A : Assessment–Search-Not furnishing the reasons-Notice and assessment–Alternative remedy is available–Writ is held to be not maintainable.[Art. 226]
S. 147 : Reassessment–No failure to disclose material facts– Reassessment is bad in law. [S. 148]
S. 147 : Reassessment-Doctrine of merger-Undisclosed investment-Issue which was subject matter of appeal-Reassessment is held to be bad in law. [S.69, 148, 153A]
S. 147 : Reassessment–No addition was made on basis of reasons recorded-No other addition could be made in course of reassessment proceedings. [S. 148]
S. 139 : Return of income–Defective return-Denial of deductions-AO must provide an opportunity to remove the defects in the return and opportunity of hearing–Order of the AO is set aside. [S.48 54F, 143(3), Art.226]
S. 139 : Return of income-Revised return–Manually- Amalgamation-revised returns of income filed by companies pursuant to scheme of arrangement and amalgamation approved by NCLT, manually, beyond prescribed period without obtaining condonation of delay from Board in accordance with section 119(2)(b) read with CBDT Circular No. 9 of 2015 were valid. [S. 119(2) (b), 139 (5), Companies Act, S. 391]