S. 237 : Refunds-Interest on refunds-Delay in issuing Form 5 certificate-Interest on refund-Department’s obligation to compensate wrongful retention of money-Assessee entitled to interest on refund for period from date of issue of form 5 till date of payment-Interest on refund directed at six per cent. for delayed period.[S. 132A 244A, Direct Tax Vivad se Vishwas Act, 2020, S 4, 5, 7 Art. 226]

S. 237 : Refunds-Interest on refund-Department directed to process claim for refund with interest under section 244A with interest in accordance with law [S.244A, Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Stay-Ex parte assessment order-Pending appeal before Commissioner (Appeals)-High pitched assessment-Assessing Officer directed to pay 20 per cent. deposit of demand-Principal Commissioner directed to deposit Rs. 5 lakhs per month-Attachment of bank account and property-On writ monthly instalment of deposit reduced to Rs. 1 lakh considering hardship caused to assessee Directions to decide appeal before Commissioner (Appeals) expeditiously Coercive proceedings for recovery of demand restrained.[S. 144, 144B, 156, 220(6), 250, Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-High pitch assessment-Recovery of Rejection of application for stay of demand Precondition of depositing 20 per cent. of demand-Stay of recovery in interim order of court until disposal of pending appeal before Commissioner (Appeals)-Direction to appellate authority to expedite disposal of appeal Interim relief granted to continue until outcome of order in statutory appeal [S. 147, 220(6), 250, Art. 226]

S. 206C : Collection at source-Trading-Forest produce-Coal sales-Public sector undertaking-Verification of form 27C declaration under section 206C(1A)-Assessee in default-Order of Tribunal quashing the order is affirmed. [S.206C(IA), 260A, Form 27C]

S. 197 : Deduction at source-Certificate for lower rate-Capital or revenue-Employee stock option-One-time compensation received for surrendering of stocks received under stock option scheme of employer-Stock option not perquisite-Order rejecting application quashed and set aside-Cost of acquisition of stock options cannot be determined Capital receipt not chargeable under section 45-Not chargeable under any other head Charging section and computation section constituted an integrated code-Application for nil deduction rejected by Principal Chief Commissioner-No adequate alternate remedy of appeal-Writ petition maintainable-Order rejecting the application was quashed and set aside. [S. 4, 5, 17(2),45, 48, Art.226]

S. 153A : Assessment-Search-No incriminating material discovered during search-Principle of finality in tax proceedings-Reassessment, revision-Multiple proceedings on same issue-Order of Tribunal affirmed.[S. 54F, 143(3), 147, 148, 153A, 260A, 263.]

S. 151A: Face less assessment scheme-Jurisdiction-Search cases Central charge-Under faceless mechanism-e-Assessment of Income Escaping Assessment Scheme, 2022 dated 29-3-20221-Central Board of Direct Taxes order dated 6-9-2021-Judicial propriety-High Court-Precedent-Proper for Bench of court to follow its own authoritative ruling in preference to that of another court.[S. 144B(2), 148, 153A, 153B, 153D [Art. 226]

S. 151A: Face less assessment scheme-Jurisdiction-Procedure adopted by Department in contravention of statutorily prescribed provisions-Notice set aside-Revenue granted liberty to proceed in accordance with law. [S. 147, 148, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Shares issued less than fair market value-Revision proceedings dropped-Change of opinion-Reassessment notice and proceedings quashed and set aside. [S.56, 147, 148, 148A(b) 148A(d), 263, Art. 226]