S. 271(1)(c) : Penalty-Concealment-Failure to specify the charge, which limb penalty proceedings initiated-Penalty quashed.

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash deposits-Detailed reply along with documentary evidence filed before Assessing Officer to explain source of Cash deposits-Order neither erroneous nor prejudicial to the interest of revenue.

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Charitable trust-Assessment Order Cryptic and without any discussion-Revision is held to be justified. [S. 11, 12A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Search and Seizure-Original assessment completed prior to date of search-No incriminating documents found during search-Revision is held to be not valid. [S. 143(3), 153A]

S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Delay in filing miscellaneous application two years 11months-No specific power conferred on Tribunal to condone delay in filing miscellaneous applications-Miscellaneous applications dismissed.

S. 251 : Appeal-Commissioner(Appeals)-Powers-Power of enhancement-Short term capital gains-No power to assess new source of income. [S. 45]

S. 195 : Deduction at source-Non-resident-Other sums-Income Deemed to accrue or arise in India Purchasing spare parts through Indian subsidiary-Business connection is established-Liable to deduct tax at source. [S. 9(1)(i)]

S. 192 : Deduction at source-Salary-Employee stock ownership plan-Stock option not perquisite-Not taxable-No liability upon assessee to deduct tax at source. [S. 17]

S. 147 : Reassessment-Non-Resident-No jurisdiction-Transfer of proceedings to competent jurisdiction-No notice was issued by Assessing Officer of competent jurisdiction-Reassessment not valid-Void ab initio. [S. 127, 148]

S. 147 : Reassessment-After the expiry of four years-Accommodation entry-No failure to disclose material facts-Reassessment is held to be bad in law. [S. 148, ITAT R. 27]