S. 147 : Reassessment-After the expiry of four years-Penny stock-Information from investigation wing-Fresh material-No change of opinion-Reassessment notice is valid. [S. 148, 151, Art. 226]

S. 144B : Faceless Assessment-A bonafide request made for personal hearing through video conferencing on the portal-window for submitting reply was closed before the stipulated time-A gross violation of principles of natural justice-Order was quashed and set aside. [S. 148, Art. 226]

S. 12AA : Procedure for registration-Trust or institution-Registration was granted after considering the genuineness Of institution-Cancellation of registration on the same provisions in the trust deed is not valid-Appeal To Appellate Tribunal-Powers Of Tribunal-Appellate Tribunal-Tribunal cannot make own case de novo. [S. 11(IA), 12AA(3), 254(1)]

S. 199 : Deduction at source – clubbing of income -Credit for tax deducted -Non -furnishing of the declaration by the deductee to the deductor – Credit for deduction of tax at source cannot be denied [ S. 64 , Rule 37BA(2) Form 26AS ]

S. 154 : Rectification of mistake -Mistake apparent from the record -Credit for TCS -Rule applicable to TDS should also be applicable TCS- Denial of claim for TCS is not valid [ S. 199, Rule , 37BA(2)(i) ]

S. 115JC : Special provisions for payment of tax by certain persons other than a company- Provisions are applicable to projects approved before the introduction of the section . [ S.80OB(10) ]

S. 68 : Cash credits – Non -Resident – Foreign bank accounts – Mentioning wrong status in the return – Once the assessee is non-resident the income or deposit in the foreign bank account cannot be taxed in India – Addition was deleted . [ S. 6(1), 56(2)(v) , 153A]

S. 264 :Commissioner – Revision of other orders – Interest received in income tax refund – Amount taxed twice – Revision power is not limited to correcting any errors committed by the tax authorities but also extended to errors committed by the assessee- Order of Commissioner was set aside . [ S, 56, 148, 246A , Direct Tax Vivad Se Vishwas Act , 2020 Art , 226 ]

S. 148 : Reassessment –Notice – After the expiry of four years –
Time limit for notice – Sanction for issue of notice – Approval was obtained from Additional Commissioner of Income -tax Instead of Principal Chief Commissioner of Income tax – Order is bad in law and quashed . [ S. 147, 149(b) 151(1)(ii) , Taxation and other laws ( Relaxation and Amendment of certain Provisions ) Act , 2020, Art , 226 ]

S. 45 : Capital gains – Long term capital gains – Unaccounted income –Purchases accepted as genuine – Shares were traded on stock exchange after paying securities transaction tax and money had been received through banking channels – Capital gains cannot be assessed as bogus long term capital gains- Deletion of addition by the Tribunal is affirmed [ S. 10(38) 133A 260A ]