S. 234A : Interest-Default in furnishing return of income-Waiver of interest–Or otherwise–Delay in filing of return was due to impounding of documents in the course of survey.[S. 234B, 234C, Art. 226]

S. 225 : Collection and recovery-Stay of proceedings–Pendency of appeal–Recovery of penalty is stayed till the disposal of the appeal. [S. 271(1)(c), Art. 226]

S. 221 : Collection and recovery–Penalty-Tax in default –Delay in remitting the Tax deducted at source-Survey – Financial stringency not proved-Levy of penalty is held to be justified. [S. 133A, 201]

S. 197 : Deduction at source-Certificate for lower rate–Application for lower tax deduction is allowed, subject to certain conditions. [S. 194-C, 194-H, 197, 201(1), 201(1A), 264, Art.226]

S. 194LA : Deduction at source–Agricultural land-Compensation on acquisition of certain immoveable property-From report of Halqa Patwari it was evident that land of assessee acquired by Government was ‘Gairmumkin’ in nature, and same was not agricultural land, compensation received by assessee in pursuance of land acquisition proceedings was subject to TDS [S 2(14)(iii), 10 (37), 45, 119, 237, Art. 226]

S. 194A : Deduction at source-Interest other than interest on securities–Deposits made by the petitioner societies with the Co-operative Banks, they would be entitled to the benefit of exemption under S.194 4A(3)(iii)(v) of the Act and, in respect of the deposits made by the petitioner societies with the Treasury, they will not be entitled to the benefit of exemption under S. 194A(3)(iii)(a) of the Act. [S.44AB, 194A(3) (iii) (v), 194A(3)(iii) (a), Art. 226]

S. 147 : Reassessment–With in four years-Commercial production-Every non-disclosure of material facts will not or cannot be a justifiable reason for reopening an assessment-What was required to be considered is that, substance over form-Order of single judge is affirmed. [S. 10B, 148, Art. 226]

S. 147 : Reassessment–With in four years-Issue of shares at premium-Mere production before the AO the Account Books, or other evidence, from which material evidence could, with due diligence, have been discovered by the Assessing Officer, would not necessarily amount to disclosure within the meaning of the First Proviso to S. 147–Court perused the Investigation report which was referred while issuing the notice of reassessment-Notice of reassessment is held to be valid-Writ petition is dismissed-Awarded costs of Rs. 1 lakhs to be paid to The Delhi High Court Advocates Welfare Trust. [S.68, 143(1), 148]

S. 147 : Reassessment–With in four years–Capital gains-Valuation-Reassessment is held to be valid–Referring the matter for valuation to the file of the AO is held to be valid. [S. 2(47)(v), 50C), 148]

S. 147 : Reassessment–With in four years-Tax frauds-Reasons to believe have been recorded in meticulous details by the AO-Approval was obtained before issue of notice-Notice of reassessment is held to be valid in law. [S. 148, 151]