S. 271(1)(c) : Penalty-Concealment-Cash credits-Recoding of satisfaction-Show cause notice did not indicate whether there was concealment of particulars of income or furnishing of incorrect particulars of such income-Deletion of penalty is held to be valid. [S. 274]

S. 264 : Commissioner-Revision of other orders-Powers-Capital gains-Full value of consideration-Escrow account-Consideration received less than the amount credited in the account-Only actual consideration taxable-Power of Principal Commissioner not restricted to allowing relief only up to returned income -Recomputation results in income less than returned income-Section 240 not applicable-Entitle to refund of excess tax paid. [S. 45, 48, 240, 264, Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue Deemed dividend-Loans and advances to shareholders-Unsecured loan from group company-Paid back with interest in same year-Revision is held to be not justified. [S. 263]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Share application money-Revision order is held to be valid. [S. 68 69]

S. 260A : Appeal-High Court-Not discussed on merits-Order of High Court set aside-Matter remanded. [Benami Property Transaction Act, 1988, S. 49]

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-Pre-deposit-For entertaining an appeal it is not mandatory for pre deposit of tax in dispute. [S. 144, 144B,220(6), 246A, Art. 226]

S. 245D : Settlement Commission-Settlement of cases-Procedure-Application-Court in writ jurisdiction cannot scrutinize or reappreciate facts, evidence or findings of Settlement Commission in reaching to its conclusion for allowing claim in settlement application. [S. 245D(1), Art, 226]

S. 201 : Deduction at source-Failure to deduct or pay-Limitation-Order is barred by limitation-limitation of two years as prescribed in section 201(3), as it existed prior to its substitution by Finance Act, 2013 with effect from 1-10-2014, would apply. [S. 200, 201(3), 201(IA)]

S. 197 : Deduction at source-Certificate for lower rate-Dividend-Rate of tax-Dividend received by a Switzerland based company from Indian company-Lower withholding tax rate of 5 per cent instead of 10 per cent in view of MFN clause-DTAA-India-Switzerland. [S. 9(1)(iv), Art. 10, Art. 226]

S. 195 : Deduction at source-Non-resident-Foreign companies-Equalization levy-Direction to deduct tax at source 10 percent-When the assessee is subjected itself to Equalization Levy of 2 per cent on payments under consideration, as an interim measure, assessee would be entitled to receive its payment from GCI subject to a deduction of 8 per cent-DTAA. [S. 115JA, 166, 195(2), 197, Art. 226]