S. 263 : Commissioner – Revision of orders prejudicial to revenue -Interest income- Business income or income from other sources – View already taken by Assessing Officer after calling for explanation and considering submission — View could not be held to be illegal or unsustainable in law — Revision is held to be not valid.

S.253: Appellate Tribunal – Maintainability of appeal — Corporate debtor against whom moratorium order passed – Institution of suit against Corporate debtor prohibited — Provisions of the IBC Code over any other enactment in case of conflicting provisions, by virtue of a non-obstante clause contained in section 238 of the IBC Code- Appeal by department against assessee is not maintainable [S.268A , Insolvency And Bankruptcy Code, 2016, S. 14, 238 , ITAT, Rules 26 ]

S. 251 : Appeal – Commissioner (Appeals) – Penalty imposed for non appearance – CIT (A) is directed to decide on merits .[ S.144, 147]

S. 206C : Collection at source – Trader in scrap – Waste -Not in the business of manufacturing – Not liable to deduct tax collection at source .

S. 201 : Deduction at source – Failure to deduct or pay –Calculation of levy of interest – Interest to be calculated from the date on which tax should have been deducted to the date on which the payee should have filed its return [ S.201(1) 201(IA) ]

S. 153A : Assessment – Search-No incriminating material found during search — Assessment completed on date of search cannot be disturbed — Assessment not valid.[ S.132]

S.147: Reassessment — Accommodation entry -Information from Director of Income-Tax- No application of mind or independent inquiry or link between any tangible material- Reassessment not valid.[ S.148 ]

S.147: Reassessment — Accommodation entry -Information from Director of Income-Tax- No application of mind or independent inquiry or link between any tangible material- Reassessment not valid.[ S.148 ]

S. 147 : Reassessment –With in four years- Change of opinion- Sale of agricultural land available on record at time of original assessment — Book profit – Agricultural Land — Gains on sale of agricultural land not deductible- Reassessment is held to be not valid [ S. 2(14((iii) , 115JB ,148 ]

S.147:Reassessment — Accommodation entries- Share application and share premium- No failure to disclose any material facts – Assessing Officer not mentioning names of parties from whom receipt of accommodation entry in reasons — Reassessment held to be not valid.[ S.68 , 148 ]