S. 271(1)(b) : Penalty-Failure to comply with notices-Non appearance was not with any malafide intention-Penalty is deleted. [S. 142(1), 271B]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Assessing Officer has applied his mind-The Principal CIT to hold bare minimum inquiry before passing the order which in the instant case has not happened. Revision order is quashed. [S. 143(3),144, 144B, 147, 263(1)(b)]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Natural justice-Not dealing on merits-Matter remanded to the CIT(A) to decide on merits. [S. 250,251(1)(a)]

S. 251 : Appeal-Commissioner (Appeals)-Powers-co-terminus powers with that of the AO-Revaluation of asset-Assessing the income under different head-Cash credits-Capital gains-Powers exercised by the CIT(A) cannot be said to be beyond the scope of provisions of s. 251(1)-What was considered by the CIT(A) is the very same income which arose out of the revaluation of the asset held by the firm. [S. 45(4), 68]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Revision-Revision order is set aside by the Tribunal-Issue subject matter of consideration or examination by a higher authority in the rank of hierarchy, the lower authority in the rank or the authority exercising equal powers cannot sit in judgment over the order passed by the higher authorities-The powers exercised by the CIT(A) under s. 251(1) to enhance the assessment towards consideration paid for purchase of property in the hands of the assessee is beyond the scope of the powers of the CIT(A)-Investment in purchase of property-Capital contribution by partners-Addition is deleted. [S.69, 153A, 251(1), 263]

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-Appeal-Non-disposal of rectification application within period of six months-Quantum od refund-AO is directed to entertain the said application under s. 154 and dispose it of as per law after verification of records. [S. 154(8),244A]

S. 154 : Rectification of mistake-Mistake apparent from the record-Order passed by the CPC without issuing any prior notice/intimation-Disallowance of PF /ESI-Jurisdictional High Court in favour of assessee-Adjustment is bad in law. [S.36(1)(va)]

S. 153C : Assessment-Income of any other person-Search-Recording of satisfaction-The documents were transmitted to the AO of the assessee, based on which he had rightly initiated the proceeding under S. 153C-The law is amendment of S. 153C w.e.f. 1st Oct., 2014-Incriminating material is found-Assessment is valid-Payment made to tenant is not in respect of said plot-Full consideration is assessable as income. [S. 132]

S. 148: Reassessment-Notice-Non-resident-Non jurisdictional AO-Revenue could not demonstrate that when the notice was issued on 30th March, 2022, ITO, Ajmer, had valid jurisdiction over the assessee-Reassessment is quashed.[S. 147]

S. 147 : Reassessment-Cash deposit-Substantial cash deposit-Return not filed-Reassessment notice is valid. [S. 68,115BBE, 148]