S. 260A : Appeal – High Court – Review –Low tax effect -Audit objection – Appeal decided as per CBDT Circular dt 8 -8 -2019- No error apparent on the face of the record Review petition was dismissed .[ S.268A]

S. 254(1) : Appellate Tribunal – Duties- Additional income offered -Confirming the levy of concealment penalty without giving an opportunity is held to be bad in law – Matter remanded to the Appellate Tribunal . [ S.271(1)(c)]

S. 254(1) : Appellate Tribunal – Duties- Charitable Trust – Computation of income -Commercial sense – Matter remanded [ S. 2(24), 2(45), 11 ]

S. 254(1) : Appellate Tribunal – Duties- Cryptic and suffers from the vice of non application of mind- Matter remanded to the Tribunal . [S.37 (1)]

S.225 :Collection and recovery -Stay of proceedings – Pendency of first appeal – Bank account cannot be attached without giving a reasonable opportunity of hearing – Attachment of bank account was set aside – Assessing Officer must objectively decide the application for stay considering that an appeal lies against his order – The matter must be considered from all its facets, balancing the interest of the assessee with the protection of the Revenue.- Directed to hear the stay application with in six weeks from the date of the order [ S. 226 , 250, Art . 226 ]

S. 158BC : Block assessment – Satisfaction – Recorded after competition of assessment – Capital gains – Transfer-A satisfaction note is sine qua non and could be prepared at either of following stages , at the time of or along with the initiation of proceedings against the person searched under section 15C of the Act , along with the assessment proceedings under section 158 BC and immediately after the assessmmeent proceeings are completed under section 158BC of the person sercched – Order of Tribunal is quashed . [ S.2(47)(v) , 45, 132 158BD ]

S. 147 : Reassessment- Reasons communicated and reasons raised are different – Recorded reason was supplied after completion of assessment – Reassessment is bad in law [ S.148 ]

S. 147 : Reassessment – Charitable Trust- Corpus donation – Change of opinion- No new facts – Reassessment is held to be bad in law [ S. 2(15) 11, 12A , 148 Art , 226 ]

S. 144 : Best judgment assessment – Addition made cash deposited during demonetization period. – Addition on account of business income – Violation of principle of natural justice –
Matter remanded to Assessing Officer [ S.142 (1), Art , 226 ]

S. 92C : Transfer pricing – Arm’s length price – Comparable – Test of functional similarity applied by Tribunal is in consonance with legal position discussed herein above— Order of Tribunal is affirmed [ S.92B(2), 260A ]