S. 271AAB:Peanlty -Search initiated on or after Ist day of July 2012-Assessment completed u/s. 143(3) – Addition made – Reopening u/s. 147 – Again additions made – Two penalty proceedings for both addition – Merging of penalty is not valid – Not specifying the charge – Barred by limitation- Penalty order is quashed . [ S. 274 ,275 ] .

S. 271(1)(c) : Penalty – Concealment – No specific limb in penalty notice – Penalty order is set aside.[ S. 274 ]

S. 271(1)(c) : Penalty – Concealment -Depreciation- The Charitable trust voluntarily withdrew the depreciation claim, and there is no deliberate concealment or misrepresentation, penalty- Penalty is deleted .[ S. 11, 32 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
Income from other sources – Purchase of immoveable property – difference in actual sale price and the stamp duty value – Addition of total stamp duty value- Matter remanded to CIT for further verification. [ S. 56(2)(x) , 69A ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
Income from other sources – Interest -Zero coupon debentures redeemable after 9 years to its directors – Premature converted in to equity – Interest amount deemed to be received upon conversion of debentures in to equity shares in relevant assessment year – Revision order is justified . [ S. 2(24)(iv) 47(x),47(x)(a), 49(2A), 56(2),(id), 145 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Disallowance of expenditure – Exempt income – Outstanding GST – Revision order is affirmed – Registration and provision for warranty – Revision is not justified . [ S. 14A ,37(1) 43B ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
Charitable purpose -Objects of general public utility – Merely because the society’s participants included members from the private sector, it does not change the fundamental non-commercial nature of its activities- The society’s role as a facilitator for the hydrocarbon industry does not make its activities commercial- Revision order is quashed .[ S. 2(15), 11, 12 12AA ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
The NFAP was already adjudicating the disallowance of transport charges u/s. 40(a)(ia), the PCIT had no jurisdiction to revise the order .[ S.40(a)(ia) ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –
Capital expenditure – The expenses in dispute were already capitalized – No prejudice to revenue – Revision order is quashed .[ S.37(1) ]

S.263 : Commissioner – Revision of orders prejudicial to revenue – Short term capital loss – Section 263 cannot be used just because the PCIT holds a different view – No finding of lack of enquiry or perversity in AO’s conclusion- Reaffirmed that revisional jurisdiction cannot substitute AO’s discretion where AO acted judiciously.[ S. 143(3) ]