S. 263 : Commissioner-Revision of orders prejudicial to revenue-Business expenditure-Specific query was raised in the original assessment proceedings-Mere failure to issue notice under section 133(6) did not warrant exercise of jurisdiction under section 263 of the Act-Order of Tribunal is affirmed-SLP of Revenue is dismissed. [S. 37(1), 133(6), 143(3), Art. 136]

S. 260A : Appeal-High Court-Delay 4 years and 100 days-Failed to give any adequate or sufficient reasons-Appeal was dismissed as time barred-SLP of Revenue is dismissed. [Art. 136]

S. 244A : Refund-Interest on refunds-Central Processing Centre (CPC)-Unable to input it foreign bank account details by imputing SWIFT code and IBAN as per ITR-Bank account is validated by revenue on 7-7-2023 and refund was made in October 2023 without interest-High Court directed the Revenue to pay interest on refund amount at rate specified in section 244A from 1-5-2022 to 5-10-2023. [S. 143(1), Art. 226]

S. 237 : Refunds-Pendency of appeal before DRP-No recoverable demand-Refund cannot be withheld to be adjustment towards anticipated demand. [S.144C(5), 220,254(1), Art.226]

S. 226 : Collection and recovery-Modes of recovery-Capital gains-Full value of consideration-Stamp valuation-Pendency of appeal-Directed to the recovery till disposal of the appeal by the CIT(A). [S. 50C, 56(2)(x), 250, Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Pendency of appeal-Direction of High Court is modified and requirement of security with respect to penalty was to be dispensed with.[S.115-O, 226, Art. 136]

S. 194I : Deduction at source-Rent-Storage charges-Storage tanks-Did not qualify either as land or as building-Not liable to deduct tax at source. [S. 201(IA), (260A]

S. 154 : Rectification of mistake-Mistake apparent from the record-Refund of tax deduction at source-Central Board of Direct Taxes-Instructions-Application was filed after 12 years from assessment year-High Court dismissed as barred by limitation-SLP dismissed as withdrawn with the liberty to make an application before CBDT.[S. 119, art.136]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction note-Served satisfaction note subsequent to notice under section 143(2)-Writ petition is dismissed.[S. 132 142(1), Art. 226]

S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Limitation-Where no satisfaction is recorded year of search has to be considered-High Court quashed the proceedings-SLP of Revenue is dismissed. [S. 132, 153A]