S. 271(1)(c) : Penalty-Concealment-Failure to indicate limb under which proceedings initiated-Penalty is deleted. [S.133A]

S. 271(1)(c) : Penalty-Concealment-Business loss-Carry forward and set off-Pendency of appeal-Claim cannot be termed incorrect or erroneous or false —Levy of penalty is not justified.

S. 271(1)(c) : Penalty-Concealment-Purchases entered with stock register-Corresponding export-Ad-hoc estimate-Penalty levied under both limbs-Penalty is deleted.

S. 271(1)(c) : Penalty-Concealment-Penalty-Notice not specifying charge-Notice not valid.[S.273B]

S. 270A:Penalty for under-reporting and misreporting of income-Penalty not leviable if ingredients specified for misreporting is not established by Assessing Officer. [S.270A(9)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Fund investors resident of various countries-Non-fulfilment of condition of Liable to tax-Tax Exemption by resident country does not give right to Revenue Authorities to tax income in contracting State —Derivatives-Contention of Principal Commissioner that income earned from derivatives not business income is not accepted-Revision order is quashed. [S. 2(29A),6, 10(23FE, 900, 90A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny assessment-Principal Commissioner issued show-cause notice entirely different from issues selected for limited scrutiny-Assessing Officer cannot go beyond reasons of limited scrutiny-Principal Commissioner cannot pass revision order on other aspects-Revision order is quashed. [S. 143(3)]

AEP Investments (Mauritius) Ltd. v. Asst. CIT (IT) (2023)108 ITR 37 (Delhi)(Trib)

S. 254(2A): Appellate Tribunal-Stay-Non-Resident having no assets in India-Directed to furnish a bank guarantee covering 20 Per Cent-Recovery of outstanding demand shall remain stayed for a period of 180 days from date of this order or till disposal of appeal, whichever ever is earlier. [S. 226]

S. 253 : Appellate Tribunal-Appeals-Memorandum of appeal-Two assessment orders-Contends are different-Matter remanded to Commissioner (Appeals) to verify and adjudicate de novo complying with principles of natural justice-Principal Chief Commissioner is directed to make a thorough enquiry.[S. 143(3), 250]