S. 263 : Commissioner-Revision of orders prejudicial to revenue– Addition to fixed assets–Disallowance u/s. 14A of the Act-Enquiries done by the AO in the original assessment proceedings-Revision is held to be bad in law. [S. 14A, R. 8D]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Introduction of capital-Loan from brother–NRI for two years-after detailed the AO has accepted the capital and loan as genuine-Revision is held to be not justified. [S. 69A]

S. 260A : Appeal-High Court–Monetary limits–Pendency of appeals-No cascading effect nor issue involved in group matters-Appeals of department is dismissed–Question is kept open. [S. 268A]

S. 254(2) : Appellate Tribunal–Rectification of mistake apparent on record-Where the issue before the Tribunal was of allowability of deduction, it was incorrect to remand the matter with a direction to apply transfer price provisions-AO had already passed the order, pursuant to such remand, and deleted the addition accordingly the writ petition had become academic. [S. 36(1)(iii), S. 92C, 254(1), Art. 226]

S. 254(1) : Appellate Tribunal-Powers-Registration–Interpretation – Powers of Tribunal are co -extensive to that of Commissioner – Tribunal can direct the Commissioner to grant the registration without reamnding matter to Commissioner. . [S.12A, 12AA]

S. 234C : Interest-Deferment of advance tax–Demerger of the unit–Not justified in levying the interest for period before acquisition of cement business by assessee-Interest is directed to be waived. [S. 119(2), Art. 226]

S. 225 : Collection and recovery-Stay of proceedings–Disputed demand-Deposit of 20 percent tax of demand is not a condition precedent-Directed to pass reasoned order. [S. 226, Art. 226]

S. 222 : Collection and recovery-Certificate to Tax Recovery Officer-Attachment and sale of immovable property-Limitation-Attachment of immovable property in 1997-Proclamation of sale in February, 2019-Barred by limitation. [Sch. II R. 68B. Art. 226]

S. 222 : Collection and recovery-Certificate to Tax Recovery Officer-Amalgamation-Tax Recovery Officer could not seek recovery of taxes of reassessment from assessee-company inasmuch as assessee neither had been served with notice of reopening of assessment, nor had any occasion to participate in such reassessment proceedings. [S. 147, 148, Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default–Stay –Penalty–Pendency of review petition-Discretion must be exercised judiciously–Rejection of application for stay of recovery of penalty is held to be without application of mind–No waiting for three days in terms of order passed-Held to be not valid. [S. 220(6), 245, 271(1)(c), Art. 226]