S. 263: Commissioner-Revision of orders prejudicial to revenue-
Penalty Concealment of income or furnishing inaccurate particulars thereof-Specific charge-Assessing Officer recording satisfaction under section 271AAB and not under section 271(1)(c) during assessment proceedings-Revisional authority’s direction to initiate proceedings under section 271(1)(c) without such satisfaction unsustainable-Tribunal justified in setting aside revisional order.[S. 260A, 271(1)(c), 271AAB.]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Penalty concealment-Satisfaction need not be recorded in particular form-Order dropping penalty proceedings can be revised.[S. 271 (1)(c)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
-Finding by Tribunal that proper enquiry had been conducted-order was not prejudicial to Revenue Order of revision not valid.[S. 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Consortium of private entities not a statutory body-Deduction wrongly allowed by AO-Revision justified-Order of Tribunal set aside.   [S.80IA(4) Expl. 263]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Number of partners exceeded 20-Remuneration to partners-Commissioner not showing how order of Assessing Officer prejudicial-Order of Tribunal quashing the revision order was affirmed. [S.40(b)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash credits-Share application money-Second revisionary order-Order of Tribunal setting aside second revisionary order is affirmed-SLP of revenue dismissed. [S. 68, 143(3), Art. 136]

S. 254(1) : Appellate Tribunal-Duties-Cash credits-Share application money-Deleting additions without assigning reasons-Matter remanded to Tribunal to consider afresh and pass reasoned order.[S 68, 260A]

S. 253 : Appellate Tribunal-Appeals-Delay of 530 days in filing appeal-Delay because assessee was pursuing rectification and review options-Delay must be condoned-Matter remanded to the Tribunal to decide on merits. [S. 80P(2)(a)(i), 260A]

S. 245D : Settlement Commission-Settlement of cases-Procedure-Application-Report by Principal Commissioner-Rejection of request for further enquiry-No adverse inferences drawn in assessment proceedings pursuant to search and seizure Nothing to establish that mere agreement of sale between two persons led to concealment of income Order of Settlement Commission rejecting further enquiry was held to be proper. [S. 132, 153A, 245C, 245D(3), Income-tax Settlement Commission (Procedure) Rules, 1997, R. 9, Art. 226]

S. 245C : Settlement Commission-Settlement of cases-Powers of Central Board of Direct Taxes-Delegated legislation-Maintainability of application-Search conducted prior to 31-3-2021 but notices under sections 153A / 153C issued thereafter-Application filed before 30-9-2021-Rejection on ground that no “case” pending as on 31-3-2021 pursuant to CBDT Order-Held, statutory requirement is pendency of a case on date of application-CBDT cannot expand definition of “case” under section 245A(b) or impose substantive eligibility conditions by delegated legislation-Clause in CBDT Order requiring pendency as on 31-3-2021 held ultra vires-Order partly reversed. [S. 119(2)(b), 132, 153A, 153C, 245A(b), Art. 226]