S. 4: Charge of income-tax – Hindu undivided family – Sole surviving coparcener – Assessable as Hindu undivided family [Indian Income-tax Act, 1922 S.3 ]

S.4: Charge of income-tax – Cash credits- Assessee must prove the source of receipt -In the absence of such proof the Assessing Officer is entitled to treat it as taxable income – Cash credits could be assessed as undisclosed income [ S. 147, Indian Income-tax Act, 1922, S.34 ]

S. 2(43): Tax – Interest and penalty is not tax [Special Court (Trial of Offences relating to Transactions in Securities) Act, 1992, S. 3, 4, 11]

S.2(22)(e): Deemed dividend – Share holder means a registered share holder and not beneficial owner [Indian Income -tax Act ,1922 , S .2(6A)]

S. 2(12A): Books of account – Entries in loose papers/ sheets are irrelevant and inadmissible as evidence- Offences and prosecution- Settlement Commission- Investigation could not have been directed in case of high public functionaries on basis of legally inadmissible evidence in form of loose papers [S. 69A, 132, 143(3), 245D; Constitution of India 1949, Art. 32; Code of Criminal Procedure, 1973, S.155(2), 156(1); Indian Evidence Act, 1872, S.34]

S. 2(1A) : Agricultural income – Agriculture – cultivation of land – tilling of land, sowing of seeds etc – Certain other operations which are performed after produce sprouts from land , can also be regarded as agricultural operations- However spontaneous growth not involving any human labour or skill upon land are not products of agriculture – Income derived therefrom is not agricultural income . [ S. 10(1) , Indian Income-tax Act, 1922, S. 2(1) 4(3)(viii)].

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 .