S. 220 : Collection and recovery-Assessee deemed in default-Stay of demand-20 per cent deposit-Financial hardship-Unconditional stay not justified. [Art. 226]

S. 158BD: Block assessment-Undisclosed income of any other person-Architect’s cross-examination confirmed cash payments made by the assessee; since concurrent findings of fact established the Assessing Officer’s satisfaction, undisclosed income was rightly assessed under section 158BD and not under section 69C. [S. 69C, 132, 260A]

S. 154: Rectification of mistake-Mistake apparent from the record-Document Identification Number-Rectification order issued without DIN and not covered by CBDT Circular exceptions-Subsequent allotment of DIN could not cure the defect-Backdated order-Notice under section 154(3) issued after the purported date of rectification order-Order barred by limitation and passed without mandatory opportunity of hearing-Quashed-Alternate remedy-Objection rejected. [S. 119, 143(3), 154(3), 154(7), Art. 226]

S. 153C: Assessment-Income of any other person-Search-No incriminating material-Notice was quashed. [S.132, 153A, Art. 226]

S. 153C: Assessment-Income of any other person-Search-Incriminating material-Writ jurisdiction-Issue to be examined in assessment/appellate proceedings-Writ petition dismissed. [S. 132, 132A, 153A, 153B, Art. 226]

S. 153C : Assessment-Income of any other person-Search-Reassessment based on material seized during search of third party-Proceedings under section 147 without jurisdiction. [S. 147, 148, 153A, Art. 226]

S. 153A :Assessment-Search-Assessment in absence of incriminating material-Addition of long-term capital gain relating to penny stock transactions-Jurisdictional prerequisite not satisfied-Addition deleted.[S. 10(38),68,260A]

S. 151: Reassessment-Sanction for issue of notice under wrong clause-For A.Y. 2017-18, sanction required under section 151(ii) and not section 151(i)-Notice quashed.[S. 148, 151(i), 151(ii), TOLA, 2020, S. 3]

S. 151: Reassessment-Sanction for issue of notice-Specified authority-Order under section 148A(d) was passed beyond three years from the end of the relevant assessment year, and approval was obtained from the Principal Commissioner instead of the specified authority required under amended section 151(ii), non-compliance with such statutory mandate and time limits vitiated the jurisdiction of the Assessing Officer, rendering the order under section 148A(d) and notice under section 148 quashed. [S. 148,148A(b),148A(d), 151(i), 151(ii), Art. 226 ]

S. 151: Reassessment-Sanction for issue of notice-Specified authority-Approval granted by the Principal Commissioner was not valid; consequently, the order passed under section 148A(d) and consequential notice issued under section 148 were held to be bad in law and were quashed and set aside. [S. 148,148A(b), 148A(d), 151(ii), TOLA, Art.226]