S.270AA: Immunity from imposition of penalty ,etc-Order passed without giving an opportunity of hearing – Matter was remanded back to consider the application of the assessee. [ S. 270A , 270AA(4), Art , 226 .]

S. 250 : Appeal – Commissioner (Appeals) – National Faceless Appeal Centre ( NFAC) -Ex-parte order – -Non -filing of grounds of appeal at the time of filing of Form No 35 – Dismissing the appeal without considering the submissions filed by the assessee – Order was set aside . [ S. 251 , Art , 226 ]

S.241A: Refunds- Withholding of refund in certain cases – Intimation order was passed – Order withholding refund was set aside and the Revenue was directed to conduct a de novo exercise as per provision of section 241A of the Act . [ Art , 226 ]

S. 197 : Deduction at source – Certificate for lower rate Binding judgement of Supreme Court – Pendency of review – Assessing Officer is bound to follow the judgement – Order has to be passed due application of mind- DTAA -India – Denmark .[S. 9(1)(vi), 195 , Art, 13(3) Art. 226 ]

S. 194A : Deduction at source – Interest other than interest on securities – Delay in payment of interest – Tax was deducted out of gross amount of interest without spreading over the period of delay – Not justified- Directed to refund the TDS deducted . [S. 2(28A),2(28B), Motor Vehicles Act, 1988 , S.168, 173, Art , 226 ]

S. 179 : Private company – Liability of directors -Recovery proceedings- Gross neglect , misfeasance or breach of duty -Not proved – Order of the Assessing Officer and order rejecting the revision application was quashed . [ S. 264, Art , 226 ]

S. 153D : Assessment – Search – Approval – Order passed without obtaining the prior approval is bad in law . [ S. 132 ,153A, 153B]

S. 153 : Assessment – Limitation – Assessment barred by limitation- Refund due to the assessee must be paid along with the interest . [ S. 153(3), 153 (4), 254(1) Art, 226 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – All original notices issued under section 148 of old regime and issued between 1-4-2021 and 30-6-2021 would stand beyond prescribed timeline of six years from end of assessment years 2013-14 and 2014-15- Assessment time barred under old regime and could not be issued as per amended provisions. [ S. 148 , 148A(b), 148A(d), 149, 151 , Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S.3 , Art , 226 ]

S. 143(3): Assessment – Assessment order without DIN (document identification number ) has not valid in law – Statutory defects in the assessment order cannot be cured by applying the provision of section 292B of the Act Circular No 19 of 2019 dated 14 -8 -209 ( 2019) 416 ITR 140 (St) –Circular of CBDT is binding on the Revenue – Order of Tribunal quashing the assessment order was affirmed . [ S. 144C, 147, 292B ]