S. 245C : Settlement Commission-Settlement of cases-Conditions-Case pending-Settlement Commission inoperative with effect from 1-2-2021-Establishment of Interim Board-Notification restricting filing of application before interim Board for settlement by assessees eligible on 31-1-2021-Settlement Commission legally existed till 31-3-2021-Last date mentioned in Notification should read as 31-3-2021-Orders rejecting applications quashed-Matters remanded to interim Board for consideration-Amendment in law-Legislative intent. [S.245A(b), Art.226]

S. 244A : Refunds-Interest on refunds-Non-Functionality of Department’s Portal-Amalgamation-Delay was not attributable to assessee-Entitled to additional interest-Interpretation of Taxing Statutes-Application of principles of equity. [S.153(5), 244A(1), 250, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Failure to furnish approval of Designated Authority along with reasons recorded-Non application of mind-Notice and order disposing of objections is set aside.[S. 147, 148, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Notice issued after four or three years-Specified Authority for approval-Approval granted by Joint Commissioner-The authority statutorily empowered to confer approval would be the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner-Notice and reassessment proceedings invalid.[S. 147, 148,148A(b), 148A(d), 151(ii)-Taxation And Other Laws (Relaxation And Amendment Of Certain Provisions) Act, 2020, S. 3. Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Notice issued after four or three years-Specified Authority for approval-Approval granted by Joint Commissioner-The authority statutorily empowered to confer approval would be the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner-Notice and reassessment proceedings invalid.[S. 147, 148,-Taxation And Other Laws (Relaxation And Amendment Of Certain Provisions) Act, 2020, S. 3. Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Failure to furnish approval of designated authority Order of High Court quashing the proceedings is quashed-SLP of Revenue is dismissed. [S. 147, 148, Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice after three years-Sanction of Specified Authority-Approval to be obtained from Principal Chief Commissioner-Approval from Principal Commissioner-Sanction is invalid-Order and consequent notice is invalid. [S.147, 148,148A(b), 148A(d), 151(ii), Art.226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Faceless assessment-International tax charges-Notices issued by Jurisdictional Assessing Officers and consequent proceedings and orders set aside-Revenue is given liberty to proceed in accordance with new procedure. [S.144B, 147, 148, 148A, 151A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Pendency of appeal-Scrutiny assessment order pending in appeal rendered infructuous-Order passed under section 148A(d) is held to be valid-Assessee is given liberty to seek appropriate remedy if adverse reassessment order is passed.[S. 143(3), 147, 148, 148A(b) 148A(d), 250, Art. 226

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Loan-Non-consideration of explanation-Duty of Assessing Officer to consider assessee’s Explanation and pass reasoned order-Non application of mind-Notice and order is quashed and set aside. [S. 147, 148, 148A(b), 148A(d), Art. 226]