S. 250 : Appeal-Commissioner (Appeals)-Procedure-Collection and recovery-Assessee deemed in default-Sufficient opportunity was provided-Order of single judge dismissing the writ petition is affirmed-Order is modified to the extent to remit 20 per cent of the disputed tax as a precondition for filing a stay petition along with the appeal before the Tribunal.[S. 220(6), 250(4), Art. 226]

S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-Appeal filed manually-Dismissal of appeal-Appellate authority is directed to take into consideration the date of filing of the manual appeal for the purposes of calculating and appreciating the issue of delay in respect of the appeal preferred online. [S. 250, Art.226]

S. 244A : Refunds-Interest on refunds-Directed to refund the amount with interest.[R. 31A,Form No 26B, Vivad Se Vishwas Act, 2020, S. 5, 6, 7, Art. 226]

S. 237 : Refunds-Delay in payment—Laxity of Department—Strictures-Refund of tax amount if any, ought to be immediately granted to assessee-Delayed payment of refunds burdens the public exchequer-Rules would be required to be framed-Accountability is required to be fixed. [S. 239, 244A, Art. 226]

S. 158BC : Block assessment-Undisclosed income-Evidence collected and noticed during the search can be considered for assessment-Cross examination of parties-Ghost of benami companies-Assessment order is correctly assessed-No substantial question of law.[S. 158BB, 260A]

S. 154 : Rectification of mistake-Mistake apparent from the record-Disallowance of expenditure-Exempt income-Assessee has accepted the disallowance-Issue is not debatable-Order of Tribunal affirming the order of CIT(A) is affirmed. [S. 14A, 260A]

S. 153C : Assessment-Income of any other person-Search-Limitation-Search in the case of husband-Seized materials which belonged to assessee were handed over to jurisdictional Assessing Officer on 20-11-2021-Assessment orders were issued on 30-3-2023 or 31-3-2023-Time limit of 12 months would run from 31-3-2022 to 31-3-2023-Assessment orders were issued within period of limitation-Issuance of notice under section 153A is triggered by search or requisition, whereas notice under section 153C is triggered only upon occurrence of three conditions-Provision of Section 69 is applicable in case of where the books of account is not maintained-Opportunity of being heard-The order under S. 127 was issued after obtaining the consent of or consulting the persons concerned. Mixed questions of fact and law cannot be decided in the absence of pleadings. [S.69, 132(9A), 153B, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued by jurisdictional AO and not as per S. 151A— Section 144B cannot be viewed as exclusive basis for all assessment and reassessment procedures and Jurisdictional Assessing Officer (JAO) cannot be completely deprived of power to assess or reassess merely because section 144B and Faceless Reassessment Scheme 2022 have been introduced S.151A-Notice issued by Jurisdictional Assessing Officer-Guidelines issued in terms of sub-S. (2) of s. 144B will not amount to the directions issued by the Central Government in terms of sub(2) of s. 151A—Writ petition is dismissed. [S. 124 143(2), 144B,148, 148A]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Final assessment order passed by AO is quashed only for the purpose of enabling the assessee to take up all objections and contentions vis-a-vis the impugned notices-On SLP the Court held that the concerned AO shall consider the objections and contentions of the assessee. [S. 148, 148A(b), 148A(d), Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice in the name of dead person-High Court by an order disposed of writ petition reserving all contentions to be taken by legal heirs of assessee before Assessing Officer except contention that initial notice under section 148A(b) was issued to a dead person-Order of High Court is modified and the AO is directed to consider all legal arguments including defect notice issued in the name of dead person. [S. 148A(b), 148A(d), Art. 136]