S. 250 : Appeal-Commissioner (Appeals)-Procedure-Territorial jurisdiction of CIT(A)-Appeal filed before non-jurisdictional CIT(A)-Order by the CIT(A) CIT(A), Noida is set aside and the matter is remanded to the CIT(A), Ghaziabad to adjudicate the appeal afresh in accordance with law. [S. 246A]

S. 199 : Deduction at source-Credit for tax deducted-Salary-Matter remanded to the file of CIT(A) for verification. [S. 192, Form no 26AS]

S. 164 : Representative assessees-Charge of tax-Beneficiaries unknown-Trust-Maximum marginal rate-Temple-Income from charity received from devotees coming to the temple and interest on bank deposits-Beneficiaries are general public-Revenue Department website also advises that the tax rate of the trust is as applicable to the individual-The tax rate as specified in S. 164(2) will apply to the AOP/Individual and the initial exemption is also available [S.2(37), 12A,164(1) 164 (2)]

S. 153 : Assessment-Reassessment-Limitation-Non-resident-The assessment was made as per the procedure laid down in S. 144C-No reference was made under S. 92CA(1)-Time-limit for completing the assessment under S. 147 was available upto 31st March, 2022-The final assessment order passed by the AO under s. 144 r/w s. 144C, dt. 12th Jan., 2023-Barred by limitation. [S.92CA, 144, 144C,147, 148 153(2)]

S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Neither reference to the date of search nor description of the nature of documents seized-Assessment order is invalid-No incriminating material was found-Addition is deleted. [S. 132]

S. 151 : Reassessment-Sanction for issue of notice-More than three years from the relevant assessment year-Sanction for the order under s. 148A(d) was obtained from Principal CIT and not Principal Chief CIT-Reassessment proceedings are quashed [S. 147 148, 148A(b), 148A(d)]

S. 147 : Reassessment-Cash deposits-Search-Salary-Investigation-Reassessment is valid-Unexplained cash-Source is not explained-Addition is affirmed. [S.68,69A, 132, 148]

S. 147: Reassessment-Cash deposit-No mentioning of name of asseessee in Investigation report-Objection not fully disposed of-Reassessment is quashed. [S.68,133(6), 148]

S. 147 : Reassessment-Non application of mind-Shell companies-Web site of the Income-tax portal-Re produced information without cross verification-The reopening of assessment is quashed.[S. 148]

S. 145 : Method of accounting-Failure to produce details-Rejection of books of account is justified-Matter is restored back to the AO to estimate the profit of the assessee at a percentage worked out on the basis of preceding three years. [S. 145(3)]