S. 271(1)(c) : Penalty-Concealment-Approval-Procedure-Tribunal was not justified in quashing penalty order passed by Assessing Officer on mere premises that Additional Commissioner did not find place in section 274(2)(b) of the Act. [S. 2(28C), 274(2)]
S. 271(1)(c) : Penalty-Concealment-Offshore bank accounts-Voluntary declaration-Levy of penalty is not valid. [S. 143(3), 147, 148]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Pendency of appeal before ITAT-Assessing Officer can complete the assessment-No demand can be enforced till the appeal is decided by the Appellate Tribunal. [S. 254(1), Art. 226]
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Work in progress-Method of accounting-Valuation of stock-Merely to remand matter to AO to verify correctness of submission made by assessee that profit element was accounted for in its income was held to be not valid. [S. 145]
S. 260A : Appeal-High Court-Delay of 174 days-Delay was condoned.
S. 260A : Appeal-High Court-Delay of 545 days-Administrative exigency-Delay was condoned.
S. 260A : Appeal-High Court-Territorial Jurisdiction-Assessment was initiated at New Delhi and final assessment was framed by Assessing Officer at Ghaziabad-High Court of Punjab and Haryana lacked jurisdiction to adjudicate matter.
S. 241A : Refunds-Withholding of refund in certain cases-Estimated tax liability-Revenue neutral-Method of accounting-Income offered for tax when services were rendered-Withholding of tax is held to be not valid. [S. 143(3), 145]
S. 234D : Interest on excess refund-Provision inserted from 1-6-2003 would apply to all regular assessments made on or after 1-6-2003 irrespective of assessment year involved-Liable to pay interest.
S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice u/s 148 issued on 30-6-2021 without complying with mandatory provisions-Order is quashed-, Explanations to Notifications dated 31-3-2021 and 27-4-2021 issued by CBDT were to be declared ultra vires of 1961 Act and TLA Act, 2020. [S. 148, 151 Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3, Art. 226]