S. 276C : Offences and prosecutions-Willful attempt to evade tax-Sanction was given to the Deputy Director for initiating prosecution proceedings; hence, prosecution had to be launched by him alone and by the Assistant Director-Matter was settled in accordance with Section 93 of the Finance (No.2) Act, 2024-SLP was to be disposed of with the observation that judgment was not to be treated as precedent for any purpose. [S. 278BB, 279]

S. 272A : Penalty-Failure to answer questions-Sign statements-Furnish information-Order of High Court was stayed by the Supreme Court vide order dated 30.05.2025-Subsequently revenue had issued a notice for penalty under section 272A-Since order of High Court was already stayed by Supreme Court, penalty notice was also to be stayed.[S.68, Art, 136]

S. 271(1)(c): Penalty-Concealment-Failure to specify the charge-No specific limb was struck off-The Tribunal was justified in deleting the penalty.[S.68, 260A, 274]

S. 268A : Appeal-Instructions-Circulars-Monetary limits-Income from other sources-Deductions-Tax effect was below the monetary threshold limit of Rs. 2 crores as per CBDT Circular No. 9 of 2024, dated 17-9-2024, appeal was to be dismissed for low tax effect. [S.56, 57(iii), 260A]

S. 264: Commissioner-Revision of other orders-82-year-old woman-Order passed by the Commissioner rejecting the application was set aside and remanded to the Commissioner to re-examine the assessment of the assessee and pass appropriate orders. [S. 139, Art.226]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Carry forward and set off of accumulated loss and unabsorbed depreciation-Amalgamation-Demerger-There was no error per se in the order of assessment, and the direction under the order of revision amounted to a mere roving enquiry and the same was set aside.[S.2(19AA), 2(IB), 72A(2), 72A(4)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Capital gains-Slump sale-assessment order did not address the issue with reference to competing provisions; exercise of power under Section 263 was justified.[S.45, 50B]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Amalgamation-Depreciation-Demerger-Goodwill-Difference between net assets and shares to be issued credited as goodwill and depreciation allowed-Scrutiny assessment-Order of Tribunal setting aside revision order was affirmed by High Court-SLP delay of 658 days-SLP dismissed on the ground of delay as well as on merits. [S.43(6), Art. 136]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record-Limitation of six months for filing a rectification application would commence from the date of communication of the order and not the date of the order itself. [S. 254(1),254(3), ITAT R. 1963, R. 9, 34A, Art. 226]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record-Once the Tribunal had partly allowed the appeal by order dated 21-9-2011 and had directed adoption of 5 per cent profit ratio by modifying the assessment order, the Tribunal was not within its power to re-adjudicate issues and determine estimated income in the hands of the assessee afresh.[S. 254(1), 260A]