S. 250: Appeal-Commissioner (Appeals)-Procedure-Failure to give a reasonable opportunity of hearing-Matter remanded to the file of CIT (A) for de novo adjudication. [S. 10(23C)(iiiad), 143(1) (a)]

S. 249: Appeal-Commissioner (Appeals)-Form of appeal and limitation-Appeal was served on 7-8-2023-Due date for filing of an appeal was 15-9-2023-Appeal was filed on 25-8-2023-CIT(A) was not justified in dismissing the appeal on the ground of delay-Cash credits-Matter was remanded for deciding on merits.[S. 68, 246A, 250]

S. 234B: Interest-Advance tax-Non-Resident-Deduction at source-Interest not leviable. [S. 195]

S. 199: Deduction at source-Credit for tax deducted-Trust-Trustee-TDS in the name of Trustee-Assessing Officer was to be directed to give due credit to assessee-trust if credit of TDS was in name of trustee and details were given whether money was credited by trustee into account of trust. [S. 143(1), 154]

S. 154: Rectification of mistake-Mistake apparent from the record-Enhance assessment or reduce refund-Order passed without giving an opportunity of hearing-Rectification order was set aside. [S. 143(3), 154(3)]

S. 154: Rectification of mistake-Mistake apparent from the record-Investment in mutual fund-Name of assessee as second holder-Order was passed without giving an opportunity of hearing-Rectification order was set aside. [S. 143(3)]

S. 153B : Assessment-Time limit-Exchange information-Reference was on 14-11-2012-Article 26 ceased to exist after 30-8-2010-Period of limitation could not be extended under Explanation (ix) to section 153B to frame assessment based on such reference-Assessment order was quashed and set aside on ground of limitation-DTAA-India-Swiss [S. 90, 90A, 153B(ix) Art.24, 26]

S. 149: Reassessment-Time limit for notice-For assessment year 2015-16, notice under section 148 issued on 29-7-2022 was beyond the limitation period prescribed under section 149 and was barred by limitation.[S. 68, 148, 148A(b), 148A(d)]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Beyond three years-Income alleged escapement was less than 50 lakhs, i.e., 32.78 lakhs-Reassessment notice and consequential assessment orders were void ab initio, hence quashed. [S. 56 (2) (vii)(b), 147, 148, 148A(b), 148A(d), 149(1)(b)]

S. 147 : Reassessment-Cash credits-Accommodation entries-Share capital-Failure to comply with filing with ROC-Huge share capital in balance sheet-Reassessment proceedings were quashed and set aside.[S. 68, 148]