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]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital asset-Lease hold right-Capital or revenue-Cancellation of allotment of plot of land-Compensation-Treated as capital-receipt Revision order was quashed. [S. 2(14), 4, 28(i)]