S. 260A : Appeal-High Court-Substantial questions of law-No challenge to High Court order-Mistake of counsel-Counsel erroneously submitting that two of them covered against assessee by decision of Supreme Court-High Court disposing of appeal deciding third question alone in favour-Order of High Court set aside to enable restoration of appeal to High Court.[Art. 136]

S. 254(1) : Appellate Tribunal-Duties-Non-resident-Permanent establishment (PE)-DTAA (India-USA)-Issue of PE not considered by Tribunal-Matter remanded to Tribunal to examine the matter afresh-DTAA-India-USA [S.90, 260A, Art. 5, 27]

S. 245H : Settlement Commission-Immunity from prosecution and penalty-Full and true disclosure-Writ petition of revenue was dismissed. [S. 245C, 245D(4), Art. 226]

S. 245D : Settlement Commission-Settlement of cases-Procedure-Application-Search and seizure-Additional income-Settlement Commission entitled to consider evidence beyond materials seized during search operation or disclosed before it-Writ petition was dismissed. [S.2(22)(e), 132, 245D(4), 245I, Art. 226]

S. 244A : Refunds-Interest on refunds-Delay in paying refund-High Court holding interest payable on interest accrued on account of refund due to delay in repayment-Delay of 444 days-SLP dismissed on account of delay and merits.[S. 136]

S. 237 : Refunds-Affidavit-Refund of Rs. 100.49 crores with interest to be released to assessee. [S. 244A, Art. 226]

S. 195 : Deduction at source-Non-resident-Other sums-Statutory authority-Retention of amounts on pretext of Income-tax contingency-Illegal-Direction to refund with interest-Costs imposed on Managing Director-Precedent-Statutory authority must be fair in its commercial transactions. [S. 201(IA), R. 31, Form 16A, Art. 12, 226]

S. 194C : Deduction at source-Contractors-Rent-Payments under charter party contracts for vessels liable under S.194C, not S.194-I. [S. 194-I, Art. 226]

S. 153C : Assessment-Limitation-Finance Act, 2017 amendment-Extension of period from six to ten years-Applicability only when search made on or after 1 4 2017. [S. 132(1), 153A, 153D, Art. 226]

S.153C : Assessment-Income of any other person-Search-Recording of satisfaction-Limitation-Preparation of satisfaction note not a mechanical process-No delay in initiation-Objection on limitation not raised before AO-Writ petition dismissed. [S.132(1), 153A, 153D, Art.226]