S. 254(1): Appellate Tribunal-Powers-Interest on borrowed capital-Lease rent-Tribunal remanded disallowance without recording findings on business purpose and diversion of borrowed funds-Remand order passed by Tribunal liable to be set aside for fresh adjudication-Any sum received from employees-Tribunal, despite recording admitted delay in payment of employees’ contribution, remanded issue without recording reasons as to allowability, impugned remand order was unsustainable and liable to be set aside for fresh adjudication. [S. 36(1)(iii), 36(1)(va), 260A]

S. 244A: Refunds-Interest on refunds-Order giving effect-Revenue was to be directed to pay interest or compensation at 6 per cent per annum on delayed payment of interest of Rs. 7.58 crores from 01-08-2023 till the date of payment of such interest. [S.244(IA) Art. 226]

S. 222: Collection and recovery-Certificate to Tax Recovery Officer-Order of Tribunal attained finality-Tax demand was paid-Tax recovery officer was directed to lift the attachment.[S. 153A, 254(1), Art. 226]

S. 158BC: Block assessment-Undisclosed income-Incriminating material-Search-Retracted statement-No evidentiary value-Order of block assessment was quashed and set aside.[S. 132, 132 (4), 158B, 260]

S. 153D: Assessment-Search and seizure-Approval-Single approval-Without reference to seized material or assessment records, such approval was invalid. [S.153A, 260A]

S. 153C : Assessment-Income of any other person-Search-Opportunity of cross-examination-Assessment founded on diaries and statement under section 132(4) of a third party-Cross-examination denied by the Assessing Officer and the Tribunal-Violation of natural justice-Matters remanded for fresh adjudication after allowing cross-examination. [S. 132(4), 143(3), 153A, 260A]

S. 153C: Assessment-Search-Other person-Date of initiation of search-Date of handing over seized material-Since initiation of search was subsequent to 1-4-2021, provisions of section 153C would not apply and thus, impugned notice issued under section 153C was to be quashed-Notice invalid. [S.132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Assessing Officer of searched party and third party was the same-Time limit of clause (ii) of third proviso to section 153B(1) shall apply which was 12 months from end of financial year in which search took place-Order was quashed. [S. 153B, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction was recorded four years after search and two years after assessment of searched person-Notice was quashed and set aside. [S.132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Loose sheets-Satisfaction note-A sheet of paper containing typed entries and in loose form, not shown to form part of books of account regularly maintained by assessee-Satisfaction note is required to be recorded under section 153C for each assessment year and where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings-Power to transfer cases-No reasonable opportunity had been provided before transferring case and officer of Bangalore had sent Notice and Assessment order to assessee who was a resident of Delhi, it was in total violation of section 127-Order of High Court affirmed-SLP of revenue dismissed. [S. 127, 132, Art. 136]