S. 271(1)(c) : Penalty-Concealment-Ground raised first time before High Court-After 23 years-Defects in the Notice-Principle of natural justice cannot be raised after 23 years-Assessee participated wholeheartedly in the penalty proceedings, however, later on before the High Court raised the objection in regard to the defect in notice-The assessee had understood the contents of the notice as to which two limbs falling u/s 271(1)(c) and complied with the SCN without raising any objection-Assessee not permitted to raise the question of fact before the Court-Hence, the Revenue’s appeal allowed. [S.260A, 274,Art. 226]

S. 264 : Commissioner-Revision of other orders-Claim under section 80IA is not made in the return-Assessment is completed u/s 143(3)-Rejection of Revision application is set aside-Remanded to the Commissioner to consider the claim on merit.[S.80IA. Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Company-Book profit-Depreciation-Consistently charging depreciation in its books of account at rates prescribed in Income-tax Rules and accounts of assessee had been prepared and certified as per provisions of Companies Act, 1956-A specific query was raised by Assessing Officer on issue of payment made to related party and verification of fair market value as per provision of section 40A(2)(b) and when answered-Order of Tribunal quashing the Revision order is affirmed. [S. 32,40A(2)(b), 115JB, 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Unexplained expenditure-Ad-hoc addition made by the Assessing Officer-Order of Tribunal quashing the direction of PCIT to do de novo assessment is affirmed. [S.69C, 26A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Business of road infrastructure and development-AO allowed the claim made under section 80IA after detailed scrutiny-Revision of assessment order on the ground that the assessee is only a work contractor-Unjustified-Rule of consistency is followed. [S.80IA, 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Expenses or payments not deductible-Cash payments exceeding prescribed limits-Order of PCIT quashing the revision order is affirmed. [S. 40A(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Expenditure on scientific research-Form 3CL filed but delay in intimation-Commissioner passed the revision order-Order of Tribunal quashing the Revision order is affirmed. [S. 35(2AB), 260A, Form No. 3CL]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Cash credits-Share capital and share premium-Record-shall include and shall be deemed always to have been included all records relating to any proceedings under this Act available at the time of examination by the Ld. Pr. CIT or Commissioner-Order of Tribunal quashing the revision order is affirmed by High Court.[[S. 68, 153A, 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash credits-Opting VSV Scheme is closure of disputes-Revision order is bad in law reopened by issuing notice under section 263 for revising assessment order-[S. 68, 260A, Direct Tax Vivad Se Vishwas Act, 2020, S.4]

S. 260A: Appeal-High Court-Delay of 2139 days-Absence of sufficient cause-Delay is cannot be condoned.