S. 237 : Refunds-Delay in payment—Laxity of Department—Strictures-Refund of tax amount if any, ought to be immediately granted to assessee-Delayed payment of refunds burdens the public exchequer-Rules would be required to be framed-Accountability is required to be fixed. [S. 239, 244A, Art. 226]

S. 158BC : Block assessment-Undisclosed income-Evidence collected and noticed during the search can be considered for assessment-Cross examination of parties-Ghost of benami companies-Assessment order is correctly assessed-No substantial question of law.[S. 158BB, 260A]

S. 154 : Rectification of mistake-Mistake apparent from the record-Disallowance of expenditure-Exempt income-Assessee has accepted the disallowance-Issue is not debatable-Order of Tribunal affirming the order of CIT(A) is affirmed. [S. 14A, 260A]

S. 153C : Assessment-Income of any other person-Search-Limitation-Search in the case of husband-Seized materials which belonged to assessee were handed over to jurisdictional Assessing Officer on 20-11-2021-Assessment orders were issued on 30-3-2023 or 31-3-2023-Time limit of 12 months would run from 31-3-2022 to 31-3-2023-Assessment orders were issued within period of limitation-Issuance of notice under section 153A is triggered by search or requisition, whereas notice under section 153C is triggered only upon occurrence of three conditions-Provision of Section 69 is applicable in case of where the books of account is not maintained-Opportunity of being heard-The order under S. 127 was issued after obtaining the consent of or consulting the persons concerned. Mixed questions of fact and law cannot be decided in the absence of pleadings. [S.69, 132(9A), 153B, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued by jurisdictional AO and not as per S. 151A— Section 144B cannot be viewed as exclusive basis for all assessment and reassessment procedures and Jurisdictional Assessing Officer (JAO) cannot be completely deprived of power to assess or reassess merely because section 144B and Faceless Reassessment Scheme 2022 have been introduced S.151A-Notice issued by Jurisdictional Assessing Officer-Guidelines issued in terms of sub-S. (2) of s. 144B will not amount to the directions issued by the Central Government in terms of sub(2) of s. 151A—Writ petition is dismissed. [S. 124 143(2), 144B,148, 148A]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Final assessment order passed by AO is quashed only for the purpose of enabling the assessee to take up all objections and contentions vis-a-vis the impugned notices-On SLP the Court held that the concerned AO shall consider the objections and contentions of the assessee. [S. 148, 148A(b), 148A(d), Art. 136]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice in the name of dead person-High Court by an order disposed of writ petition reserving all contentions to be taken by legal heirs of assessee before Assessing Officer except contention that initial notice under section 148A(b) was issued to a dead person-Order of High Court is modified and the AO is directed to consider all legal arguments including defect notice issued in the name of dead person. [S. 148A(b), 148A(d), Art. 136]

S.148:Reassessment—Deceased-Insolvency proceedings— Once the assets were taken over by the Official Assignee and the assessee was declared as an insolvent, the respondents can very well approach the Official Assignee for seeking their remedy—It is upto the Official Assignee to consider the claims and distribute the proceeds in accordance with law. [S. 147,152(2), 226(3), 263, Art. 226]

S. 147 : Reassessment-Commission-Non-Resident-Commission paid to services rendered out side India-Commission for the services rendered outside India, were not chargeable and consequently, the returns were accepted— The contention of the Department that they sought to invoke the proceedings to rectify the mistake, has no merit-Writ petition is allowed. [S. 9(1)(i), 143(3), 148, 195, Art. 226]

S. 147 : Reassessment-With in four years-No new tangible material-Review is not possible-Reassessment notice and order disposing the objection is quashed. [S. 13(1)(d)(iia), 115BBC, 143(3), 148, Art. 226]