S. 254(1) : Appellate Tribunal –Duties – Alleged AI-generated order – Bias apprehension – Transfer of case – Once the ITAT President reassigned the matter to another Bench, writ petition seeking deferment of hearing became infructuous .[Art. 226, 227]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Special category States – Manufacture of essential oils and perfumery -Assessment without incriminating material – Search assessment – Deduction u/s 80IC – Revisionary power cannot be exercised in respect of completed/unabated assessments in absence of incriminating material – Revision order quashed. [S. 80IC, 132, 143(3), 153A, 153C , 153D]

S. 9(1)(vii) : Income deemed to accrue or arise in India – Fees for technical services (FTS) – Functional Service Agreement – Standardized support services – No managerial, technical or consultancy element – Not taxable as FTS- DTAA – India–Belgium . [S.9(1)(vi)), Art. 12(3)(a), 12(3)(b)]

S. 143(3) : Assessment – Principles of natural justice – Assessment order passed without considering reply to notice u/s 133(6) and by relying on non-existent case law – Artificial Intelligence (AI )- Quasi-judicial authorities cannot rely blindly on results generated by AI tools without independent verification- Breach of natural justice – Alternative remedy – Appeal was filed to avoid limitation- -Assessment quashed and matter remanded [S. 68, 133(6), 144B , 156, 271AAC, 274, Art. 226]

S. 69C : Unexplained expenditure -Bogus purchases – Estimate of alleged bogus purchases – No substantial question of law – Appeal of revenue was dismissed . [ S. 260A ]

S. 254(2) : Appellate Tribunal – Rectification of mistake apparent from the record – Subsequent decision of Supreme Court – Employee’s contributions (EPF/ESI) -Tribunal cannot invoke section 254(2) on basis of subsequent change in law – Order of rectification quashed . [S. 36(1)(va), 139(1), 143(1), 260A, Art. 226, 227]