S. 263 : Commissioner-Revision of orders prejudicial to revenue-limited scrutiny-Optionally convertible cumulative preference shares at premium-Circulars would not be applicable vis-a-vis power under section 263-Discretion exercised by Commissioner under section 263 could not be restricted vis-a-vis limited scrutiny under CASS-Tribunal’s order needed to be re-examined as Tribunal either had substituted or expanded reasoning of Commissioner, thus, matter was to be remitted to Tribunal for reconsideration afresh. [S. 56(2)(viib), 68, 260A, Rule 11UA]

S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-e-filing of appeal-Appeal filed manually-CIT(A) is directed to hear the appeal on merits-Order of single judge is affirmed-Whether the question as to whether R. 45 of the IT Rules must be treated as mandatory or directory, is left open. [S. 246A, R. 45, Art, 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Pendency of appeal before CIT(A)-Twenty per cent of disputed tax demand is not a pre-requisite for putting in abeyance recovery of demand pending first appeal in all cases-Matter remanded to the Commissioner of Income tax for fresh adjudication. [S. 220(6), Art. 226]

S. 153A: Assessment-Search-Cash credits-Furnished all documents and had explained source of credit in its original return,-Deletion of additions by the Tribunal is affirmed. [S.68, 260A]

S. 153 : Assessment-Limitation-Uploading of order on web portal-One day delay in uploading of order or generating DIN would not make assessment order unsustainable in law-Writ petition is dismissed. [S. 68, 153 (3), 282, R. 127 Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Sale of land-Value was more than what has been disclosed-Writ petition is dismissed.[S. 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Search and seizure-Circular transactions-Artificially inflation of turnover-Order is passed after considering the detailed reply-Writ is dismissed.[S. 148, 148A, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accommodation entries-No change of opinion-Non-disclosure of primary facts-Audit objection-Can constitute information on basis of which re-assessment proceeding can be initiated.[S. 132A, 147, 148, 148A(b), 148A(d), 153A, 153D, Art. 226]

S. 148 : Reassessment-Writ-Kar Vivad Samdhan Scheme, 1998 Maintainability-Dismissal of writ petition without reasons order-Order is set aside and High Court is directed to hear and dispose of the writ petitions on their merits expeditiously.[S. 147, Kar Vivad Samdhan Scheme, 1998, Art. 136, 226]

S. 147 : Reassessment-With in four years-Employment of new workmen-Matter is remanded back to single judge to examine for want of jurisdiction. [S.80JJAA, 148, Art. 226]