S. 245D : Settlement commission-where Commission had taken note of each of objections raised by Commissioner in his report and after testing same against disclosure of income made by assessee in his application, proceeded to dispose of matter by impugned order, there being no perversity in order passed by Commission, petition was to be dismissed. [S.245C, 245D(4)]

S. 245C : Settlement Commission-Settlement of cases–Clubbing of shareholding held by different shareholders to make collective shareholding of 20 per cent is not permissible under law–Rejection of application is held to be justified. [ S. 132 ]

S. 226 : Collection and recovery-Assessee deemed in default-Stay-Rejection of stay application by a single line order stating petition rejected – Order set aside and directed the tax authorities to pass speaking order. [S. 220]

S. 154 : Rectification of mistake-Deduction at source-Interest other than interest on securities–Merger-Order of Commissioner (Appeals) stood merged with order of Tribunal, and further with subsequent orders of High Court and Supreme Court; hence, there did not remain or survive any jurisdiction with Commissioner to seek any rectification or correction in his earlier order–Rectification order was quashed. [S.194A, 201(1), 201(IA), 250]

S. 148 : Reassessment–Notice–Notice against dead person-Merely because in response to notice issued against Jayantilal Harilal Patel petitioner had informed Assessing Officer about death of assessee and asked him to drop proceedings- it could not, by any stretch of imagination, be construed as petitioner having participated in proceedings and, therefore, provisions of section 292B would not be attracted –Notice is held to be invalid. [S. 2(7) / 2(29), 159, 147 292B]

S. 147 : Reassessment–Two set of reasons–Gist of reasons same–Sanction was obtained–Mere fact that tax authorities conveyed reason twice would not be fatal -Reassessment is held to be valid. [S.143(1), 148]

S. 147 : Reassessment–Notice–Non disposal of objection by observing that it was not feasible to pass separate speaking order in respect of objections raised-It is mandatory to decide objections one way or other-Not curable defects-Non-adjudication of objections after receiving same, would render consequential actions and orders illegal. [S. 144, 148]

S. 147 : Reassessment-Cash credits–Gift from non relative-Suspicion – Reassessment is held to be not valid. [S.68, 143(1), 148]

S. 147 : Reassessment-After the expiry of four years- Acceptance of loans and deposits-Otherwise than by account payee cheque or account payee bank draft–reassessment proceedings was merely based on change of opinion of Assessing Officer, impugned order passed by Tribunal up held. [S. 148, 269SS]

S. 115JB : Book profit-While computing book profit, provision made for payment of wealth tax could not be included in it as section 115JB only refers to income-tax paid or payable or provisions made therefor –No question of law. [S. 260A]