S. 263 : Commissioner-Revision of orders prejudicial to revenue-Lack of application of mind to return and documents filed by assessee and failure to conduct enquiry-Revision is held to be valid.

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Initial assessment year-Claim was accepted without proper enquiry–Reassessment is valid. [S. 80IC, 143(3)]

S. 260A : Appeal-High Court–Merger of order–Composite order being questioned before the court was rejected earlier-Appeal is held to be not maintainable. [S. 32(2), 72, 254(2)]

S. 254(1) : Appellate Tribunal–Duties-Tribunal denying Deduction without giving an opportunity to be heard-Matter remanded. [S. 80P(2), 80P(4)]

S. 244A : Refunds–Interest on refunds-Appellate Tribunal directing Assessing Officer to calculate interest based on Supreme Court and High Court Decisions-Assessing Officer cannot traverse beyond scope of such order-Existence of alternative remedy is not bar to exercise of writ jurisdiction when the order is passed is bad in law and when authority exceeds his jurisdiction. [Art. 226]

S. 244A : Refunds–Interest on refunds-Amount seized–Shown as advance tax-Return accepted-Entitled to interest. [S. 132B(4)]

S. 226 : Collection and recovery-Modes of recovery -Property of guarantor given as collateral to bank-Secured creditor has priority of charge over income-tax dues-Order of attachment by tax recovery Officer is set aside. [Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002, S. 13(2), 25(E) , Art. 226]

S. 197 : Deduction at source-Certificate for lower rate–Capital gains-Sale of shares by non-resident—Rejection of application on ground that transaction of sale of shares was not genuine—Rejection of application is held to be not Justified-Substance over form- piercing the corporate veil -DTAA -India- Mauritius. [S 9(1)(i),90 ,195 Art , 13 . ]

S. 195 : Deduction at source-Non-resident-Royalty-Licence fee for use of software-Liable to deduct tax at source–Levy of interest is valid – DTAA-India–USA. [S. 90, 201(1), 201(IA), Art. 12(3)]

S. 158BC : Block assessment–Valuation of cost of construction- Valuation report was available before the date of search-No incriminating material was seized during search-Addition is unsustainable. [S. 60, 132]