S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Shell company – Natural justice – Reply was filed in response to notice under the old regime – Order passed without considering the objection was set aside – Directed to pass the order considering the objections filed by the assessee. [S.143(2), 148, 148A(b), 148A(d), Art , 226 ]

S. 271(1)(c) : Penalty-Concealment-Addition was deleted-Cancellation of penalty is valid. [Art. 136]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Loss on account of sale of shares-Shares were undervalued-Revision is justified. [S. 263(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Share transaction-Assessing Officer applied his mind-Order of Tribunal quashing the revision order was affirmed-Appeal-High Court-Condonation of delay-Administrative reasons-The Principal Commissioner had casually termed the delay of 109 days as a delay of only of “few days” which indicated the lack of seriousness on the part of the Department in adhering to the timeline stipulated under the Act. Delay of 109 days was not condoned-Monetary limits-Includes appeal against revision order-Appeal is not maintainable [S. 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Operating loss-Assessing Officer applying mind and accepting operating loss-Possible view-Revision is not justified. [S. 28(i), 37(1)]

S. 250 : Appeal-Commissioner (Appeals)-Duties-Search and Seizure-Block assessment-Failure to furnish all material in Department’s possession-Direction issued to CIT(A) to furnish to assessee except documents relied upon. [S. 132, 153A, 246A, Art. 226]

S. 246A : Appeal-Commissioner (Appeals)-Stay-Payment of 20 Per Cent. of sum assessed-Best judgement assessment-High pitched assessment-Coercive proceedings to be kept in abeyance. [S. 144, 250, Art. 226]