S. 254(2A) : Appellate Tribunal-Stay-Provision for automatic vacation of stay on completion of 365 days, whether or not assessee responsible for delay in hearing appeal-Discriminatory and arbitrary-Proviso to be read to provide for vacation of stay on expiry of periods in question only where delay attributable to assessee-The expression “permissible” policy of taxation would refer to a policy that is constitutionally permissible. If the policy is itself arbitrary and discriminatory, such policy will have to be struck down. [Art. 14, 226]

S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Tribunal has the power to rectify errors in its order. [S. 36 (1)(iii)]

S. 254(1) : Appellate Tribunal-Powers-ex parte order-Tribunal is required to dispose of the appeal on merits after hearing the respondent-Order passed by Tribunal holding that the Assessee is not interested in prosecuting the appeals is unsustainable. [ITAT R. 24]

S. 254(1) : Appellate Tribunal-Duties-Has to consider factual and legal aspects raised before it-Carbon credit-Sale of carbon credit-Capital receipt-Order of Tribunal held to be perverse. [S. 4, 80IA]

S. 245R : Advance rulings-Jurisdiction Of Authority-Issue involved in applications pending before Income-Tax Authority-Applications Barred. [S. 245R (2)]

S. 245R : Advance rulings-Application Jurisdiction of authority-issue of notices prior to filing of application-Questions raised in notices and questionnaires not connected with questions raised in application -Bar not attracted and application to be admitted for hearing. [S. 1150, 142(1), 143(2), 245R(2)]

S. 245R : Advance rulings-Procedure-Application-Notices issued prior to date of filing application cannot be a bar for admitting the application-issues involved not pending before any income-tax authority-Application admitted. [S. 245R(2)]

S. 245C : Settlement Commission-Settlement of cases-Finance Bill 2021-Denial of right to file an application before Settlement Commission-Order of single judge modified interim stay of proceedings of notices were granted, subject to final outcome of the writ petition. [S. 143(2), 153B, 153C Art. 226]

S. 241A : Refund-Withholding of refund in certain cases-Determination of tax liability not in domain of High Court except when an appeal is preferred-On going assessment cannot be challenged by filing writ petition-High Court does not have jurisdiction to consider liability to tax. [S. 260A, Art. 226]

S. 195 : Deduction at source-Non-resident-Wholly Owned Mauritius subsidiary of International Cricket Council-Payment for availing of rights in respect of grant of tickets, boards and branding etc-Neither royalty nor fees for technical services-Not liable to deduct tax at source- Payments as regards games played in India subject to withholding tax at rates in force at relevant times-DTAA-India-Mauritius. [S. 10(39), 115A(1)(b)(AA), 115BBA, 194E, Art. 7, 12]