S. 246A : Appeal – Commissioner (Appeals) – Appealable orders –
Order giving effect to order of High Court not containing decision on any issue or computation of income — Not appealable —Period from which interest has to be calculated on outstanding demand — Appealable order. [ S. 80HHC ,80IB , 154 , 220 (2) , 234D ,244A,246 ]

S. 206C : Collection at source – Survey – Buyers manufacturing beedis from tendu leaves sold by assessee — Liability only to extent of tax collection at source on such Sales and not on whole sale amount — Matter remanded for verification- Interest with effect from 1-7-2012 Liable to pay interest from date on which tax collectible to date of furnishing of return by respective buyers excluding period prior to 1-7-2012 [ S.206C(7) ,form , 27BA, 27C ]

S. 154 : Rectification of mistake – Commissioner (Appeals) granting deduction on basis of decision of High Court — Decision subsequently reversed by full bench — Order rectifying and disallowing the interest is held to be justified [ S.80P(2)(a) (i) , 250 ]

S. 153A : Assessment – Search- No incriminating documents were found in the course of search- Items already disclosed in original return of income and balance-sheet to revenue department and such assessment have completed prior to date of search and no assessment was abated. [ S.68 ]

S.147: Reassessment —Sale of property by mischief and forgery — Neither disclosing sale transaction nor offering capital gains- Reassessment held to be justified- Addition is held to be justified . [ S.148 ]

S. 147 : Reassessment – Search and seizure — Information received from investigation wing —Not independently verified from record —Correct course of action would have been to proceed under section. 153C and not under section 147 – Reassessment was quashed [ S. 132, 148 ,153C ]

S.147: Reassessment —High premium with share application money – No tangible material — Mere information that assessee had received a high premium, cannot be said to be a reason to form belief that income of assessee had escaped assessment- Reassessment notice is held to be bad in law [S. 68 , 143(1) ]

S.147: Reassessment —Housing project – Information in subsequent year – Not competition of the project – Assessing Officer need not conclusively prove income chargeable to tax escaped assessment at stage of notice — Reassessment notice is held to be valid- If flat purchaser de facto in exclusive possession of dry Balcony attached with flat, area of dry balcony includible while computing Built-up area of flat- Building Completion Certificate and the Occupation Certificate .not issued by the local authority – Not entitle to deduction u/s 80IB (10 of the Act [ S.80IB(10) ,148 ]

S.147: Reassessment — Capital gains — Agricultural Land- Change of user by Panchayat or land revenue authorities -Not showing positive income – Reassessment notice is held to be not valid [ S.2(14)(iii),10(37) ,133A, 148 ]

S.147: Reassessment — Under invoicing of export invoices -Reassessment notice entirely based on the M. B. Shah Commission report without application of mind – Held to be not valid-Period during which lockdown was in force in country due to COVID 19 pandemic was to be excluded for purpose of computing time set out for pronouncement of judgment by Tribunal i.e. within 90 days from date of hearing . [ S.148, 255 , ITAT R. 34(5) ]