S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Accommodation entries -Notice was issued under section 148 of the Act (Unamended Act )- Directions given by the Supreme Court in Ashish Agarwal were applicable to cases , where notices under section 148 had been issued during period 01 st April to 30 th June 2021 – Notice issued under section 148A(b) is held to be bad in law [S. 148A(b), 148A(d), Art , 226 ]

153A: Assessment in case of search or requisition – Examination or cross Examination – Principles of Natural Justice – If statements are not going to be used against the petitioner – Right of cross examination is not required – Writ petition was dismissed . [S. 132, 132(1), 132(1A) 292C, Art. 226]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Penny stock – Long term capital gain and short-term capital gain- Failure to provide bifurcation -Writ petition dismissed . [S. 10(38), 45, 148, 148(a)(d), ]( Art , 226 ]

S. 147: Reassessment – Pendency of rectification proceedings – Reassessment proceedings is held to be not valid – Order of High Court set aside and the order passed by the ITAT is restored . [S. 80HHC , 143(1), 148, 154 (7) ]

S. 132: Search and Seizure – Reasons to believe -Discretionary jurisdiction – Alternative remedy- Writ petition was dismissed . [ Art . 226 ]

S. 12AA: Registration of Trust Deed – Cancellation of Registration -Once registration has been granted under section 12AA after satisfying about genuineness of the activities of the Trust, the same cannot be cancelled on the basis of the same set of provisions of the Trust- . [S.12A, 12AA (3)]

S. 271G : Penalty-Documents-International transaction-Transfer pricing-Failure to furnish information within stipulated time-Absence of CFO-Reasonable cause-Penalty was deleted. [S. 92D(3), 274]

S. 271B : Penalty-Failure to get accounts audited-Derivative transaction-Turnover-Guidance note issued by ICAI on tax audit under section 44AB net result in derivative transaction to be considered as turnover-Not liable for penalty. [S. 44AB]

S. 271(1)(c) : Penalty-Concealment-Software maintenance-Royalty-Fees for technical services-Divergent views-Levy penalty is not valid. [S. 9(1)(vi), 9(1)(vii)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Commission to non-Resident-Pendency of application before AAR-Revision is held to be not valid. [S. 40(a)(i), 195]