S. 263 : Commissioner – Revision of orders prejudicial to revenue -Cash credits- Share capital- AO had made enquiry by seeking information from Switzerland Tax Authorities through proper channel of FT & TR division of CBDT, for exchange of information so as to verify identity, source of funds and creditworthiness of holding company and its promoters- Revision is held to be not justified. [S. 68]

S. 254(1) : Appellate Tribunal-Additional ground–validity of the assessment can be challenged at any time as it goes to the root of the matter and is a legal issue.

S. 254(1) : Appellate Tribunal—Duties-Additional ground- Validity of assessment is legal in nature–Admitted. [S. 153C]

S. 253 : Appellate Tribunal-Limitation-Delay of 285 days-No material prove bona fides attempts made in filing appeal, mere self-serving documents cannot condoned the huge delay-Appeal was dismissed. [S. 246A]

S. 246A : Appeal-Commissioner (Appeals)–Non filing of appeal in electronic form-Appeal cannot be dismissed on Technical grounds during changeover period.

S. 221 : Penalty—Failure to pay self-assessment tax—amendment prescribing mandatory charge of interest—Amendment does not envisage penalty for non-payment of self-assessment tax. [S.140A(3), 221(1)]

S. 153C : Assessment-Income of any other person-Search and Seizure—Issue of notice is mandatory-The amendment in S.153C by the Finance Act, 2017, with effect from April 1, 2017 to the effect that the block period for the person in respect of whom the search was conducted as well as the “other person” would be the same six assessment years immediately preceding the year of search was prospective in nature-Order is held to be bad in law. [S.132, 153B(1)(b)]

S. 153C : Assessment-Income of any other person-Search and seizure—Satisfaction note is not available-Assessment is held to be bad in law. [S. 153A]

S. 147 : Reassessment-Deposit in bank–Merely on the basis of deposit made in bank, reassessment is not valid when there is contradiction between statement recorded and information of recording reasons. [S. 148]

S. 143(3) : Assessment–Assessment of amalgamating company-Notices were issued prior to the amalgamation with another company–Assessment proceedings cannot be held to be invalid. [S.142(1), 143(2)]