S. 271AAB : Penalty-Search initiated on or after Ist day of July 2012-Surrender of income in the course of search-Failure to disclose in the return-Penalty is justified in respect of difference added as undisclosed income-Limb under which penalty is to be levied spelt out and assessee not offered explanation-Limitation-Tribunal passing order in quantum appeal on 27-9-2019 and penalty order passed on 23-3-2020-Order is within prescribed time-limit-No violation of principle of natural justice. [S.271AAB(1)(c), 274(1), 275(1)]

S. 271(1)(c) : Penalty-Concealment-Not specifying the charge in the notice-Levy of penalty is not justified-Estimated addition of 100 Per Cent. of purchases reduced to 30 Per Cent. of purchases by Commissioner (Appeals)-Estimated addition involving inherent subjectivity-Penalty is not warranted. [S. 274]

S. 271(1)(c) : Penalty-Concealment-Not specifying the charge–Failure to strike off irrelevant portion of notice-Penalty is not sustainable. [S.274]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains-Investment of gains in residential house within time specified-Purchase of land with intention of constructing house-Time of three years from date of transfer of original asset allowed-Revision on ground that purchase was beyond two years allowed for purchase of house is not proper.[S. 45, 54F, 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains-Short-term capital loss-Unquoted equity shares-Valuation of market value is not in accordance with Rule11UA(1)(c)-Control and management of companies are with related parties-Transactions are not at arm’s length-Revision is justified. [S. 263, Explanation 2, R.11UA(1), Companies Act, 2013, S. 53]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Merely because explanations and documents not filed before Assessing Officer during assessment proceedings-Revision is not valid.

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Assessing Officer has properly verified issues during original assessment-Expenditure on exempt income-Query raised in the course of assessment proceedings-Reply filed-Employment of new employees-In continuation of earlier years-Revision is not valid-Revision order is quashed-Revision on issue not included in notice-Revision is beyond scope of notice and not permissible. [S. 14A,80JJA, 143(3), R.8D]]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revision Lease equalisation charges-Method of accounting-Following Accounting Standard-19 in respect of rent and lease charges paid-Debiting lease equalisation charges to profit and loss account, but adding it back to total income-Assessing Officer carrying out required enquiries-Assessment order is not erroneous and prejudicial to revenue.[S. 145, Accounting Standard-19]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Discrepancy in sales promotion expenses-Clarified by assessee-Plausible view after relevant inquiries-Revision is not valid.[S.37(1), 143(3), Explanation 2 to S. 263]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Survey-Surrender letter-Business income-No findings were recorded by the Principal Commissioner how the deeming provisions were applicable and the order passed by the Assessing Officer was erroneous-Survey operation at business premises alone cannot be basis for revision.[S.68, 699, 69B, 69C 69D, 115BBE, 133A]