S. 4 : Filing of declaration and particulars to be furnished-Pendency of appeal-Condonation of delay-Appeal admitted prior to January 2020-Appeal pending-Directed the respondent to process the declaration. [S. 2(1)(a), Art. 226]

S. 2(f) : Disputed tax-Amount payable by declarant-Interest-Interest granted under section 244A cannot be recovered by revenue authority under Direct Tax Vivad se Vishwas Act, 2020, by adding same to amount of disputed tax payable by assessee. [S. 3, IT ACT, S. 234D, 244A, Art. 226]

S. 2(1)(a)(ii) : Appellant-Locus standi-Rejection of application on the ground that there is no clarity of Legal Heirs-Appeal was filed beyond limitation period-Rejection of application was held to be not valid-Directed the Designated Authority to accept the declaration [S. 3, 4(1), IT Act, S. 132, Art. 226]

S. 264 : Commissioner-Revision of other orders-Interest receipt was shown as capital receipt-Commissioner refusing to follow the order of Tribunal and dismissing the revision application-Order of Tribunal is binding on the Commissioner-Order of Commissioner was quashed-If any judgements to be relied the Commissioner should give an opportunity to the petitioner to deal with those judgements-Matter remanded. [S. 4, Art.226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Exempt income-Strategic investment-View taken by Assessing Officer being a possible view could not have been interfered by Commissioner-Order of Tribunal quashing the revision was affirmed. [S. 14A, R. 8D, 260A]

S. 220 : Collection and recovery-Assessee deemed in default-Interest-Order of CIT(A) directing to withdraw investment allowance was set aside by the Tribunal-Settlement Commission reducing the interest payable by assessee-Writ of revenue to set aside the order of Settlement Commission was dismissed. [S. 32A, 145, 220(2), 245D(4), Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Paid 20 percent of disputed demand-Assessee cannot be held to be assessee deemed to be in default-Adjustment of refund without giving an intimation u/s. 245 of the Act is held to be bad in law-Directed to refund with accumulated interest. [S. 245, Art. 226]

S. 215 : Interest payable by assessee-Advance tax short of assessed tax-Fresh assessment made by Assessing Officer giving effect to Commissioner’s revision order constitute a regular assessment-Entitle to waiver of interest only to extent stated in order under Rule 40(1). [S. 139(8), 215(4), 215(6), 263]

S. 153A : Assessment-Search or requisition-No incriminating material was produced nor stated in the notice-Notice was quashed as the respondent has failed to specify the seized documents. [S. 132, 132A, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-After the expiry of four years-Approval and reasons recorded of same date-Sanction was not properly obtained-Reassessment notice was quashed. [S. 147, 148, Art. 226]