S. 254(1): Appellate Tribunal- Powers- Ex -parte order – Search – Alleged Accommodation entry provider – 32,000+ beneficiaries- Shell companies -Alleged Money Laundering – Direction issued by the Tribunal to AO to intimate/report to SEBI, ED, MCA and ROC regarding details of money laundering activities-Directed the Assessing officer to share information about all beneficiaries within 90 days – Ex -parte order was quashed – Direction of the Appellate Tribunal was set aside – Tribunal must try and confine itself to the question that really arises in the appeal before it and not travel outside the ambit of its jurisdiction and express opinions prejudicial to the assessee which may help the Department in taking proceedings against the assessee – Court directed the Tribunal decide on merits . [S. 68, 132, 150, Prevention of Money- Laundering Act, 2002; 11, Art. 226]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Information – Internal Audit objection- Not permissible – Change of opinion -Information not based on the objection raised by the Comptroller and Auditor General of India – Reassessment impermissible- Change of opinion- Audit objection raised by CAG a view deviating from that which was taken in the course of original assessment order is change of opinion -Impermissible . [ S. 45, 48, 50C, 148 ,148A(b), 148A(d), 151 Art. 226 ]

Direct Tax Vivad Se Vishwas Act, 2020.
S. 4 : Filing of declaration and particulars to be furnished-Delay in filing of an appeal-Pending-Pendency of appeal. [S. 2(1)(a), 10, Art. 226]

S. 281B : Provisional attachment-Fixed deposit of two banks-Recording of satisfaction-Mere apprehension that huge tax demands were likely to be raised on completion of assessment was not sufficient to constitute formation of opinion for purpose of provisional attachment-Order of provisional attachment is held to be illegal.[Art. 226]

S. 276CC : Offences and prosecutions-Failure to furnish return of income-Filed belated return and also deposited amount of tax along with interest for delay which was accepted by authority concerned-No sentence could be imposed u/s 276CC of the Act [S.. 153A, 279(1). Code of Criminal Procedure, 1973, S 397]

S. 276C : Offences and prosecutions-Willful attempt to evade tax-Failure to disclose capital gain tax-Civil suit-Cost of Rs.50000 was expunged-Writ petition was dismissed-Civil Judge was directed to dispose the case preferably within a period of twelve months. [Indian Evidence Act, 1872, S.120, Art. 226]

S. 271(1)(c) : Penalty-Concealment-Additions was deleted-Penalty order was quashed.

S. 268A : Appeal-Instructions-Circulars-Monetary limits-Tax liability below 1 crore-Department appeal was dismissed.[S. 260A]

S. 264 : Commissioner-Revision of other orders-Rejecting the prayer for withdrawal of revision petition-Deciding on merit-Order set aside and remanded. [Art.226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny-Mismatch of amount paid to related persons-Verification of expenditure-The issue which was not subject matter of limited scrutiny-Revision order to disallowance of expenditure under section 14A was quashed.[S. 14A, 40A(2)(b), 57]