S. 263 : Commissioner-Revision of orders prejudicial to revenue-Transfer of shares-Capital gains-Colourable device-Dividend distribution tax-Merely recipient of income and was not entity which had either declared or paid dividend, revisionary proceedings were not justified-DTAA-India-Singapore [S. 45, 47(iv), 115-0, 260A, Art. 13]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Commercial substance-Royalty-Fees for technical services-Order of the Tribunal quashing the revision order is affirmed-DTAA-India-Singapore. [S. 9(1)(vi), 9(1)(vii), 260A, Art. 12]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital asset-Solitary transaction-Sold without development-Assessing Officer accepted the claim as capital gains-Two plausible view-Order of High Court quashing the revision order is affirmed.[S. 2(14), 45, Art. 136]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Depreciation-Order passed by Assessing Officer relying on the decision of Tribunal-Subsequently set aside by High Court-Revision is not valid-Order of High Court is affirmed. [S. 32, 143(3), Art. 136]

S. 254(2A): Appellate Tribunal-Stay-No coercive or precipitative steps had been taken by revenue-Stay petition cannot be dismissed as premature-Matter remanded to the Tribunal to decide on merits. [S. 92C, Art.226]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record-Limitation-Appellate Tribunal has no power to condone the delay-The Appellate Tribunal being a creature of the Statute cannot extend its jurisdiction beyond what is expressly conferred on it under the Statute-Order of Tribunal is set aside. [S.254(1), 260A]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Disciplinary proceedings against Commissioner (Appeals)-Tribunal remanded the matter to the Assessing Officer-Delay in initiation of disciplinary proceedings against respondent, six months prior to retirement of respondent, was fatal-Writ petition of Revenue is dismissed. [Art. 226]

S. 244A : Refund-Interest on refunds-Wrong PAN Number by the Depositor-The Revenue cannot be responsible-Not entitle to interest on refunds. [S.194C, Form No 16A, Art. 226]

S. 234C : Interest-Deferment of advance tax-COVID-19 pandemic-Dismissal of waiver application is set aside-Matter remanded to CCIT for a denovo consideration. [S.208, 209, Art. 226]

S. 234B : Interest-Advance tax-Non-Resident-Not liable for payment of interest-SLP of Revenue is dismissed due to low tax effect. [Art. 136]