S. 271(1)(c) : Penalty–Concealment–Gift received by minor son-Addition confirmed on the ground of human probabilities-Levy of penalty is held to be not valid. [S. 153A]

S. 264 : Commissioner-Revision of other orders–Accumulation of income-Mistake in form no 10-Delay in filing the form–CIT is directed to consider whether cogent reason exists for condonation of delay. [S. 11(2), 12AA, 139(4A), Form No 10, Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue– Interest on NPA-AO passed the order after due consideration of the submission-Revision is held to be not justified.[S. 145]

S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record –Bogus purchases–Estimation of profit at 1.5 % of on sales and purchases- Re hearing of appeal is not permissible in law-Writ against the rectification is held to be not bonafide – Cost of Rs 10000 is imposed on each of the petitioners. [S.69C, 254(1), Art. 226]

S. 147 : Reassessment–Change of opinion-Re assessment on the basis of subsequent assessment year where in deduction u/s. 80IA was not allowed-No tangible material having live link with the formation of belief-Reassessment notice is quashed. [S. 148, Art.226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Sale of goods-Stock in trade–Reassessment notice is held to be bad in law. [S. 148, Art.226]

S. 144C : Reference to dispute resolution panel-Time limit– Tribunal remanding matter back to DRP-Time limit is to be computed after TPO passes the order and not from the date of DRP order. [S. 144C(5), 144C(13)]

S. 143(3) : Assessment–Remand by the Tribunal-Additional claim could be made in remand proceedings–Order of tribunal is set aside. [S. 144, 254(1)]

S. 139 : Return of income-Permanent Account Number (PAN)– Dispute between members of the society-Income tax Act does not allow both groups to file income tax returns having same PAN-AO is directed to pass a reasoned order with in period of eight weeks. [Art. 226]

S. 132(4A) : Search and seizure–Presumption–Appellate Tribunal-Duties-loose papers found during search-Not absolute–Order of Tribunal is set aside.[S. 158BC, 254(1)]