S. 263 : Commissioner – Revision of orders prejudicial to revenue – Amalgamation – Accumulated Loss and unabsorbed depreciation – Both conditions to be satisfied concurrently- Sick Industrial Companies (Special Provisions) Act, 1985, Act override those of the 1961 Act- Additional depreciation – Revision is held to be not valid .[ [S.72(2) 72A , Sick Industrial Companies (Special Provisions) Act, 1985, S. 18 32(2) ]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record – Duty of Tribunal to decide on merits – Appeal dismissed ex- parte for non prosecution- Granted liberty for recall of order – Application for recalling the order rejected on ground of limitation – Date of communication or knowledge, actual or constructive, of the orders sought to be rectified or amended under S. 254(2) of the Act becomes critical and determinative for the commencement of the period of limitation- Rejection of rectification is held to be not valid . [ S.254(1) ,Appellate Tribunal) Rules, 1963, R. 24 , 35 ]

S.226: Collection and recovery – Stay- Pendency of appeal -High pitched assessment -Notional rent -Prima facie case for grant of stay [ S.12A , Art , 226 ]

S.226: Collection and recovery -Appeal Against assessment pending before Tribunal — High Court will not interfere- Department was directed to release the buses solely for use in college activities – Tribunal is directed to take up the stay petition and appeal for hearing and disposal forthwith . [ S. 12AA, 153A , Art .226 ]

S. 179 : Private company – Liability of directors -Inability to recover dues from company — Revenue should establish inability to recover due from the Company. [ Art .226 ]

S. 179 : Private company – Liability of directors – Auction sale of attached property – A going concern by virtue of order of National Company Law Tribunal does not alter situation of default of tax [ Art .226 ]

S. 158BD : Block assessment – Undisclosed income of any other person – Search on partners- Assessment in status of Association of persons Justified — Levy of interest u/s 158BFA(1) is held to be valid . [ S.184 158BFA(1) ]

S. 158BC : Block assessment – Search and seizure – The authorities are under an obligation to examine the validity of the search and only thereafter proceed to initiate the block assessment proceedings- Addition made as undisclosed income is held to be bad in law [ S.132 132A, , 292CC ]

S.147: Reassessment — Return submitted — Notice on ground that returns had not been submitted — Loan transactions accepted in original assessment —Notice seeking to assess outstanding liability as income from other sources — Held to be not valid [ S. 56, 148 , Art .226 ]

S.147: Reassessment —Book profit – Provision for bad and doubtful debt- Oder of the AO was in accordance with the judgement of the Supreme Court – Subsequent retrospective amendment withdrawing deduction — Notice based on amendment is held to be not valid .[ S. 115JA , 115JB 148 ]