S. 251: Appeal-Commissioner (Appeals)-Powers-Direction to file the rectification application-Matter remanded to the file of CIT (A) for proper adjudication of claim under section DTAA. [S.90, 154, Rule 128, Article 24 of OECD Model Convention, Form 67]

S. 250: Appeal-Commissioner (Appeals)-Procedure-Ex-parte order-Violation of the principle of natural justice-The matter was remanded back to the Commissioner (Appeals) for consideration of the assessee’s plea. [S. 144, 153A]

S. 250: Appeal-Commissioner (Appeals)-Procedure-Ex-parte order by CIT(A)-Reassessment-Land development-Directed to provide one more opportunity of hearing. [S. 45, 147, 148]

S. 250: Appeal-Commissioner (Appeals)-Procedure-Failure to give a reasonable opportunity of hearing-Matter remanded to the file of CIT (A) for de novo adjudication. [S. 10(23C)(iiiad), 143(1) (a)]

S. 249: Appeal-Commissioner (Appeals)-Form of appeal and limitation-Appeal was served on 7-8-2023-Due date for filing of an appeal was 15-9-2023-Appeal was filed on 25-8-2023-CIT(A) was not justified in dismissing the appeal on the ground of delay-Cash credits-Matter was remanded for deciding on merits.[S. 68, 246A, 250]

S. 234B: Interest-Advance tax-Non-Resident-Deduction at source-Interest not leviable. [S. 195]

S. 199: Deduction at source-Credit for tax deducted-Trust-Trustee-TDS in the name of Trustee-Assessing Officer was to be directed to give due credit to assessee-trust if credit of TDS was in name of trustee and details were given whether money was credited by trustee into account of trust. [S. 143(1), 154]

S. 154: Rectification of mistake-Mistake apparent from the record-Enhance assessment or reduce refund-Order passed without giving an opportunity of hearing-Rectification order was set aside. [S. 143(3), 154(3)]

S. 154: Rectification of mistake-Mistake apparent from the record-Investment in mutual fund-Name of assessee as second holder-Order was passed without giving an opportunity of hearing-Rectification order was set aside. [S. 143(3)]

S. 153B : Assessment-Time limit-Exchange information-Reference was on 14-11-2012-Article 26 ceased to exist after 30-8-2010-Period of limitation could not be extended under Explanation (ix) to section 153B to frame assessment based on such reference-Assessment order was quashed and set aside on ground of limitation-DTAA-India-Swiss [S. 90, 90A, 153B(ix) Art.24, 26]