S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Number of partners exceeded 20-Remuneration to partners-Commissioner not showing how order of Assessing Officer prejudicial-Order of Tribunal quashing the revision order was affirmed. [S.40(b)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash credits-Share application money-Second revisionary order-Order of Tribunal setting aside second revisionary order is affirmed-SLP of revenue dismissed. [S. 68, 143(3), Art. 136]

S. 254(1) : Appellate Tribunal-Duties-Cash credits-Share application money-Deleting additions without assigning reasons-Matter remanded to Tribunal to consider afresh and pass reasoned order.[S 68, 260A]

S. 253 : Appellate Tribunal-Appeals-Delay of 530 days in filing appeal-Delay because assessee was pursuing rectification and review options-Delay must be condoned-Matter remanded to the Tribunal to decide on merits. [S. 80P(2)(a)(i), 260A]

S. 245D : Settlement Commission-Settlement of cases-Procedure-Application-Report by Principal Commissioner-Rejection of request for further enquiry-No adverse inferences drawn in assessment proceedings pursuant to search and seizure Nothing to establish that mere agreement of sale between two persons led to concealment of income Order of Settlement Commission rejecting further enquiry was held to be proper. [S. 132, 153A, 245C, 245D(3), Income-tax Settlement Commission (Procedure) Rules, 1997, R. 9, Art. 226]

S. 245C : Settlement Commission-Settlement of cases-Powers of Central Board of Direct Taxes-Delegated legislation-Maintainability of application-Search conducted prior to 31-3-2021 but notices under sections 153A / 153C issued thereafter-Application filed before 30-9-2021-Rejection on ground that no “case” pending as on 31-3-2021 pursuant to CBDT Order-Held, statutory requirement is pendency of a case on date of application-CBDT cannot expand definition of “case” under section 245A(b) or impose substantive eligibility conditions by delegated legislation-Clause in CBDT Order requiring pendency as on 31-3-2021 held ultra vires-Order partly reversed. [S. 119(2)(b), 132, 153A, 153C, 245A(b), Art. 226]

S. 245A : Settlement Commission-Settlement of cases-Search & seizure-Proceedings under S.153A deemed pending from date of search-Applications filed before 30-9-2021 maintainable-Orders rejecting applications unsustainable-Applications restored to Interim Board-Interpretation-Anomalous results to be avoided and legislative intent behind deletion of provisions to be effected.  [S. 119, 132, 139, 147, 148, 149, 151, 153A, 245C, Art. 226]

S. 237 : Refunds-Interest on refund-Application for rectification Petition seeking direction for early disposal of rectification application-No objection by Department-Direction for adjudication of application expeditiously.[S. 154, Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Pendency of appeal before CIT(A)-Mode of undertaking transactions-Penalty levied-Attachment of bank account-Directions issued to lift attachment on condition of payment of sum-Stay of proceedings until outcome of order in appeal.[S. 12A, 80G, 250,269ST, 271DA, Art. 226]

S. 226 : Collection and recovery-Stay of demand-Pendency of appeal before CIT(A)-CBDT Circular-No statutory requirement of pre-deposit under the Act-Direction to deposit 20% of disputed demand based solely on CBDT Office Memorandum dated 31-7-2017-Executive instructions cannot override or impose conditions contrary to statute-Where serious prejudice likely and case treated as non-priority by Department, exemption from pre-deposit ought to be granted-Order rejecting stay set aside and recovery and penalty proceedings stayed [S. 119, 246A, 250, 271F, 274; Art. 226]