S. 197 : Deduction at source-Certificate for lower rate-Capital or revenue-Employee stock option-One-time compensation received for surrendering of stocks received under stock option scheme of employer-Stock option not perquisite-Order rejecting application quashed and set aside-Cost of acquisition of stock options cannot be determined Capital receipt not chargeable under section 45-Not chargeable under any other head Charging section and computation section constituted an integrated code-Application for nil deduction rejected by Principal Chief Commissioner-No adequate alternate remedy of appeal-Writ petition maintainable-Order rejecting the application was quashed and set aside. [S. 4, 5, 17(2),45, 48, Art.226]

S. 153A : Assessment-Search-No incriminating material discovered during search-Principle of finality in tax proceedings-Reassessment, revision-Multiple proceedings on same issue-Order of Tribunal affirmed.[S. 54F, 143(3), 147, 148, 153A, 260A, 263.]

S. 151A: Face less assessment scheme-Jurisdiction-Search cases Central charge-Under faceless mechanism-e-Assessment of Income Escaping Assessment Scheme, 2022 dated 29-3-20221-Central Board of Direct Taxes order dated 6-9-2021-Judicial propriety-High Court-Precedent-Proper for Bench of court to follow its own authoritative ruling in preference to that of another court.[S. 144B(2), 148, 153A, 153B, 153D [Art. 226]

S. 151A: Face less assessment scheme-Jurisdiction-Procedure adopted by Department in contravention of statutorily prescribed provisions-Notice set aside-Revenue granted liberty to proceed in accordance with law. [S. 147, 148, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Shares issued less than fair market value-Revision proceedings dropped-Change of opinion-Reassessment notice and proceedings quashed and set aside. [S.56, 147, 148, 148A(b) 148A(d), 263, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-UOI v. Rajeev Bansal (2024) 469 ITR 46 (SC)-Order and notices not in accordance with amended procedure under Finance Act, 20212 and barred by limitation.[S. 147, 148, 148A(b),148A (d), 149-Finance Act, 2021 Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice issued by jurisdictional Assessing under old regime Effect of Supreme Court decision in UOI v. Ashish Agarwal (2022) 444 ITR 1 (SC)-Writ petition dismissed-Liberty granted to file an appeal.[147, 148, 148A(b) 148A(d),246A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice issued pursuant to directions of Supreme Court in UOI v. Ashish Agarwal (2022) 444 ITR 1 (SC)-Notice signed digitally on 31-3-2021 and placed on portal-Notice dispatched through e-mail sent and speed post on 1-4-2021-Where notice sent electronically, date of dispatch of e-mail to be considered as date of issue of notice not barred by limitation [S. 147, 148, 148A(b), 148A(d), 149(1), Art. 226]

S. 147 : Reassessment-No fresh tangible material-Change of opinion-Claims under section 35AC and deductions under section 80G examined and allowed in scrutiny assessment-No new material found to reopen completed assessment-Reassessment not valid. [S. 35AC, 80G, 143(3) 148, Art. 226]

S. 147 : Reassessment-Search and seizure-Assessment of third person-S. 153C is an enabling provision and does not automatically override S. 147-In absence of satisfaction note and transfer of seized material by Assessing Officer of searched person, jurisdiction under S. 153C not assumed-Reassessment under S. 147 valid-Tribunal erred in holding that S. 153C had overriding effect merely because search was conducted-Matter restored to Tribunal to decide other grounds. [S. 132, 147, 153C, 260A]