S. 271(1)(c) : Penalty – Concealment – Employee Stock ownership Plan- Tax was deducted at source- Mistake of tax consultant – No intention to conceal income or deliberate default on part of assessee – Levy of penalty is not justified .

S.271(1)(c): Penalty — Concealment – Not recording of satisfaction -Penalty is held to be not valid .

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Advancing loans on hundi– Cash credits – Books of account not rejected – Assessing officer has passed a detailed order while dealing and adjudicating the issues – Revision order is quashed .[ S. 68 ,143(3)

S.254(1) Appellate Tribunal – Pronouncement of orders — Extraordinary situation In Light of Covid-19 Pandemic and lockdown — Period of Lockdown days to be excluded .

S. 246A : Appeal – Commissioner (Appeals) – Appealable orders –
Order giving effect to order of High Court not containing decision on any issue or computation of income — Not appealable —Period from which interest has to be calculated on outstanding demand — Appealable order. [ S. 80HHC ,80IB , 154 , 220 (2) , 234D ,244A,246 ]

S. 206C : Collection at source – Survey – Buyers manufacturing beedis from tendu leaves sold by assessee — Liability only to extent of tax collection at source on such Sales and not on whole sale amount — Matter remanded for verification- Interest with effect from 1-7-2012 Liable to pay interest from date on which tax collectible to date of furnishing of return by respective buyers excluding period prior to 1-7-2012 [ S.206C(7) ,form , 27BA, 27C ]

S. 154 : Rectification of mistake – Commissioner (Appeals) granting deduction on basis of decision of High Court — Decision subsequently reversed by full bench — Order rectifying and disallowing the interest is held to be justified [ S.80P(2)(a) (i) , 250 ]

S. 153A : Assessment – Search- No incriminating documents were found in the course of search- Items already disclosed in original return of income and balance-sheet to revenue department and such assessment have completed prior to date of search and no assessment was abated. [ S.68 ]

S.147: Reassessment —Sale of property by mischief and forgery — Neither disclosing sale transaction nor offering capital gains- Reassessment held to be justified- Addition is held to be justified . [ S.148 ]

S. 147 : Reassessment – Search and seizure — Information received from investigation wing —Not independently verified from record —Correct course of action would have been to proceed under section. 153C and not under section 147 – Reassessment was quashed [ S. 132, 148 ,153C ]