S. 271AAA : Penalty – Search initiated on or after 1st June, 2007 – Undisclosed income and specifies manner in which such income derived- Failure of the raiding party to elicit a response from assessee regarding manner of deriving income- Deletion of penalty by the Tribunal is held to be valid . [ S.132 (4) , 271AAA(2) ]

S. 92CA :Reference to transfer pricing officer -International Transactions — Transactions with Associated Enterprises —Arm’s Length Price — Management fees- Order of Tribunal is affirmed .[ S.92C, 260A ]

S. 69 :Unexplained investments – Capital gains- Sale of property – Stamp valuation-Legal fiction cannot be invoked to make addition – Merely on the basis of stamp valuation addition cannot be made .[ S.45 , 50C , 69B ,263 . ]

The Direct Tax Vivad Se Vishwas Act, 2020.

S.4: Filing of declaration and particulars to be furnished -Settlement of Disputes — The Designated Authority cannot reject the declaration filed under section 4(1) of the DTVSV Act, when the declarant’s case does not fall under section 4(6) and in any of the disqualifications mentioned in section 9 of the said Act. [S. 4(1), 4(6) ,9, ITAct , S. 264 , Art , 226 ]

S. 271(1)(c) : Penalty-Concealment-Disallowance of professional fees and interest on borrowed capital-Levy of concealment penalty is held to be not valid. [S. 36(1)(iii), 37 (1)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revised return-Substitution of sub-section (5) of section 139 vide Finance Act, 2016 which came into force from 1-4-2017 is prospective in nature-Revision is held to be valid. [S. 139(4), 139 (5)]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Additional evidence-Cash credits-No opportunity was given to the AO-Rule 46A is violated. [S. 68, R.46A]

S. 244A : Refund-Interest on refunds-Prior to 1-6-2016-Self assessment tax-Tax deduction at source-Entitle to interest. [S.156, 254(1)]

S. 234E : Fee-Default in furnishing the statements-Returns prior to 1-6-2015, no fee for period of default can be levied. [S. 200A]