S. 220 : Collection and recovery – Assessee deemed in default – Stay – Pendency of appeal before CIT(A) – Application for stay of recovery can be made before the CIT(A) to stay the demand still disposal of appeal by the CIT (A) [ S. 115Q, 220 (6) , 246A, 264 , Art .226 ]

S. 154 : Rectification of mistake – Pendency of appeal or revision is no bar on the AO on power of amendment or rectification -Matter did not assume character of a sub-judice matter . [ S.154(IA) , Art .226 ]

S. 220 : Collection and recovery – Assessee deemed in default – Stay – Relevant consideration – Conflicting decisions of Tribunal- Complete stay of demand may be granted -Decision of Jurisdictional High Court is binding on the CIT(A) – Stay was granted [ S. 220(6) , Art .226 ]

S.147: Reassessment – Change of opinion- Amortisation of barnd value – Query raised and responded – Issue examined in the original assessment proceedings – Reassessement is held to be bad in law [ S.115JB 148 , Art .226 ]

S. 244A : Refund – Interest on refunds – Tax deducted at source – Quatitifucation of interest – Interest would be pyable from the respective assessment years – Starting point for computing the interest payble must be to the assessment year in which the tax was deducted at source .[ S. 195(2) , 199 244A(1)(a) ]

S. 271(1)(c) : Penalty – Concealment – Search and seizure- Return filed after search action- Income returned was accepted -In the absence of addition no penalty can be levied . [ S. 132 , 153C, 271C ]

S.147: Reassessment -Failure to file return- Huge loss – National and muticommodity exchange – Objections stating that no income was erned and suffered heavy loss not considered – Reassessment is held to be bad in law .[ S. 139 , 148 Art. 226 ]

Interpretation of taxing statutes – Constitution of India
Art. 141 : Precedent – SLP dismissal – Non-speaking order -It does not constitute a declaration of law under Article 141 of the Constitution, or attract the doctrine of merger. [ Art, 136 ]

S. 244A: : Refund – Interest on refunds – Unauthorized retention of money by the Department – The Department is directed to pay interest as prescribed .