S. 271(1)(c) : Penalty-Concealment-Non-filing of return-Filing of financial statements and tax audit report and payment of taxes-Bona fide inadvertent human error-No concealment or furnishing of inaccurate particulars-Penalty deleted. [Art. 226]

S. 260A : Appeal-High Court-Review-Mistake apparent from record-Reassessment-Writ petition was filed after one year of assessment order-Dismissal of writ petition on ground of alternative remedy-Violation of principles of natural justice-Order recalled and writ petition restored.[S. 144, 144B, 147, 148, 260A(7), Art. 226]

S. 260A : Appeal-High Court-Delay of 40 days-Service of ITAT order on Chartered Accountant not specifically authorised to accept service-Chartered Accountant not a recognised agent of assessee-Tribunal bound to communicate order to assessee-Delay condoned. [S. 254(3), 282, ITAT R. 35, Code of Civil Procedure, 1908,Order, 3, 5, R. 12]

S. 245C : Settlement Commission-Settlement of cases-Full and true disclosure-Assessees disclosed entire receipts and offered part thereof as income after claiming balance as expenses-Deeper factual enquiry required-Rejection of application at stage of s. 245D(2C) not justified-Matter to be proceeded with under s. 245D(4)-Consequent transfer to Interim Board under s. 245AA. [S. 245AA, 245D(2C), 245D(4), Art. 226]

S. 244A : Refund-Interest on refund-Direct Tax Vivad Se Vishwas Act, 2020-Belated grant of refund-Court empowered to award interest for delay attributable to Revenue [Direct Tax Vivad Se Vishwas Act, 2020, S. 4, 5(2), 6, 7, Art. 226]

S. 239 : Refunds-Limitation-Revised return-Condonation of delay-Application for condonation beyond six years from end of AY not maintainable-Assessee cannot take benefit of his own wrong-Interest under S. 244A not payable where delay attributable to assessee-Revenue to consider only claim of refund. (S. 119(2)(b), 139(5), 244A, Art. 226)

S. 237 : Refunds-Defective return-Rectified return filed-Return cannot be ignored merely due to TDS mismatch-Where no addition made in scrutiny, refund claim must be processed. [S. 139(9), 143(3), 153C, Art. 226]

S. 206C : Collection at source-Trading-Alcoholic liquor-Forest produce-Scrap-Compounding fee and fine collected from offenders of illegal mining or transportation-No legislative mandate to collect TCS on compounding fee/fine collected under S. 23A of the MMDR Act-Obligation to collect TCS applies only to royalty payable by lawful lease or licence holders-Order of Tribunal set aside. [S. 2(47), 206(IC), Mines and Minerals (Development and Regulation)Act, 1957, S.9, 23A, Rules 2015, R. 71(5)]

S. 201 : Deduction at source-Failure to deduct or pay-Assessee in default-Limitation-Order passed beyond period prescribed under section 201(3) is barred by limitation-Liberty granted by Court to proceed “in accordance with law” does not override statutory limitation-Order and notice quashed. [S. 153(6)(i), 194C, 201(3), Art. 226]

S. 158BE : Block assessment-Time limit-Search and seizure-Deemed seizure-Limitation to be reckoned from date of conclusion of last search and not from date of initial search-Block assessment order held within limitation. [S. 132(1), 132(3), 158BC, 260A]