S. 151 : Reassessment – Sanction for issue of notice – Issuance of Notice requires the sanction of PCIT where the Notice is issued after 4 years – Relaxation Act not a bar for appropriate sanction- Reassessment notice is held to be bad in law . [ S. 147, 148 , Art , 226 ]

S. 148: Reassessment – Notice-Constitutional validity – The delegation authorized being only for the purpose of enlarging limitation under a valid law, such delegation could not be exercised to resurrect the provision of law that stood omitted from the statute book by virtue of its substitution made by the Finance Act, 2021, w.e.f. 01.04.2021 – Reassessment notices issued under section 148 of the Act are quashed-It is left open to the assessing authority to initiate – re-assessment proceedings in accordance with the provisions of the Act, as amended by the Finance Act, 2021 after making due compliance as required under the law. [S. 147, 148A, 149, 151, 151A, 153, 292 Relaxation of Certain Provisions) Act, 2020 (TOLA), S. 3(1) of the Act 38 of 2020, Art. 226]

S. 271AA : Penalty-Failure to keep and maintain books of accounts-Documents-Specified domestic transactions (SDTs)-2 per cent of value of SDTs Exceeded qualifying amount of Rs. 5 crores-Transaction with relative was only to Rs. 1.80 lalks-Term relative as given in section 2(41), which will prevail for understanding connotation of term relative under section 40A(2)(b) over one given in Explanation to section 56(2)(v) of the Act-Levy of penalty was held to be not justified. [S. 2(41), 40A(2)(b), 56(2(v),92BA, 92D, 92E]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Commissioner has not pointed out any error for the relevant assessment year-Revision is held to be not valid. [S.40(a)(1), 92CA]

S. 254(1) : Appellate Tribunal-Powers-Pandemic-Request for an adjournment of six months was rejected-Directed to fix the hearing on 24-5-2021.

S. 251 : Appeal-Commissioner (Appeals)-Powers-Amounts not deductible-Deduction at source-Non-resident-Reimbursement of expenses- Cost of allocation-Not passed reasoned order-Matter remanded to CIT(A). [S. 9(1)(vii), 40(a)(i), 195, 250, 254(1)]

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Common order-Failure to mention Assessment year 2014-15-Matter remanded. [S. 154, 254(1)]

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Reference to DVO-Failure to deal with various issues raised by the assessee-Matter remanded. [S.44F, 69A, 142A, 250(6), 254(1)]

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Principle of natural justice-Written submission-Right to be heard was not waived-Order was set aside. [S. 254 (1)]

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-Protective assessment converted into substantive assessment-Recovery proceedings-Appealable order [S. 143 (3), 153A, 156]