S.147: Reassessment – After the expiry of four years – Loans and advances to sister concern – Allegation of colourable device – No failure to disclose material facts – Notice of reassessment and order disposing objection was quashed . [S. 69, 148 , Art , 226 ]

S. 292CC : Authorisation and assessment in case of search or requisition-Separately in the name of each person-Validity-Search was conducted after introduction of section 292CC and not by applying provision retrospectively-Amendment is clarificatory in nature-Challenge to constitutional validity of section 292CC was rejected. [S. 132,132A, Art. 226]

S. 264 : Commissioner-Revision of other orders-Withdrawal of application-Rejection of prayer for withdrawal of application-decided the application on merit-Directed the Commissioner to decide the application for withdrawal as expeditiously as possible. [Art. 226]

S. 254(1) : Appellate Tribunal-Duties-Remand by High Court-Industrial undertakings-Infrastructure development-Industrial Park-Tribunal is required to record finding of its own and could not merely remand matter to Assessing Officer. [S. 80IA(4)(iii]

S. 226 : Collection and recovery-Modes of recovery-Stay-Deduction at source-Interest-Bank deposits-Failure to deduct or pay-Application for stay of demand was dismissed-Directed to deposit 20 per cent of total demand-DTAA-India-China. [S. 201 (1), Art. 11(3), Art. 226]

S. 194N : Payment of certain amounts in cash-Tax deduction at source-Cash withdrawal-Primary agricultural co-operative societies (PACCSs)-Challenge to circular was dismissed-If primary agricultural co-operative societies qualify for exemption, they should seek redressal from competent authority as provided in section 194N. [Art. 226]

S. 178 : Company in liquidation-Proceeding admitted for Corporate Insolvency Resolution Process (CIRP) under Insolvency and Bankruptcy Code, 2016 (IBC)-National Company Law Tribunal (NCLT)-Assessment order was set aside and matter was to be restored to file of Assessing Officer and matter shall be kept in abeyance till completion of CIRP. [Insolvency and Bankruptcy Code, 2016, S. 14, 238]

S. 158BC : Block assessment-Agreement with third parties-Search-Received entire amount from distributors much before release of film-Addition of balance amount as undisclosed income was justified. [S. 158BD]

S. 153C : Assessment-Income of any other person-Search-Validity-Jointly conducted-Three persons and firm-Firm would not require to be dealt with under section 153C, but would be under section 153A; however, if material collected in search against such person is used against other person, then proceeding can be taken under section 153C and not under section 153A-Matter remanded. [S. 153A, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Natural justice-Only three days time was given-Defect committed by revenue was a curable defect and if law permits, revenue can issue fresh letter to assessee in continuation to notice issued under section 148A(b) by giving him at least seven days time. [S. 148, 148A(b). 148A(d), Art. 226]