S. 263 : Commissioner-Revision of orders prejudicial to revenue-Accumulation of income-Corpus donation-Issue dealt in revision proceedings was unrelated in character from issue of corpus donation received by assessee which was dealt in re-assessment proceedings-Revision order was beyond period of two years-order is barred by limitation-Revision is quashed and set aside.[S. 11, 12A 143(1), 147, 148]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Government-funded educational institution-Assessing Officer has allowed the exemption based on a correct appreciation of facts and applicable law-Revision order is set aside. [S. 10(23C)(iiiab)]
S. 251 : Appeal-Commissioner (Appeals)-Powers-Ex-parte assessment order-Foreign tax credit-Order is set aside-DTAA-India-USA [S. 90, 139(1), Form No.67, Art. 25]
S. 220 : Collection and recovery-Assessee deemed in default-No order or notice of demand was issued-Not liable to pay interest. [S.156, 220(2)]
S. 201 : Deduction at source-Failure to deduct or pay-Deducting lower tax in earlier months of financial year-Short fall is made good in next month-Not liable to pay interest. [S. 192(3), 201(IA)]
S. 201 : Deduction at source-Failure to deduct or pay-Local Authority-Leave encashment-liable to deduct tax considering the exemption limit up to 3 lakhs-Revenue authorities are directed to recompute the quantum of tax deductible. [S.10(10AA), 201(1), 201(IA)]
S. 194A : Deduction at source-Interest other than interest on securities-Intermediary between clients-Not required to deduct TDS under section 194A in respect of payment made to its clients.[S. 2(28A)]
S. 153A: Assessment-Search-Unabated assessments-No incriminating material was found during search-Addition is deleted. [S. 14A, 132, 132A, 147, 148]
S. 144C : Reference to dispute resolution panel-DRP order was uploaded on ITBA portal on 26-5-2022-Assessment was to be completed on or before 30-6-2022-Assessment order passed on 1-7-2022 was null and void is barred by limitation.[S.92CA, 144C(13)]
S. 115J : Company-Book profit-Adjustment-Exempt income-Matter remanded.[S. 14A, R.8D]