S.271D: Penalty-Takes or accepts any loan or deposit-Assessing Officer not recording satisfaction in assessment order that there had been violation of section 269SS-High Court quashed the penalty order-SLP dismissed.[S. 269SS, Art. 136]

S. 271(1)(c) : Penalty-Concealment-Not specifying the charge in the notice-None of relevant columns had been indicated nor had irrelevant columns been struck off-Penalty notice was invalid in law-SLP dismissed. [S. 274, Art. 136]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Unsecured loans-AO raised queries, examined identity, creditworthiness and genuineness of creditors, and took a plausible view-General observation by PCIT without specific finding as to what inquiry was lacking-Revision order not sustainable. [S. 143(3), 153A]

S. 263: Commissioner-Revision of orders prejudicial to revenue-AO allowed deduction under section 54B after detailed inquiry-View taken by AO reasonable and plausible-Twin conditions for section 263 not fulfilled-Revision order not sustainable. [S. 54B, 260A]

S. 254(1) : Appellate Tribunal-Powers-Expert opinion of technical matters-Inspection of factory to decide the matter-Not perverse or any excess of jurisdiction. [S. 260A]

S. 245C : Settlement Commission-Settlement of cases-Conditions-Applications of petitioners were validly filed before ITSC which legally and factually existed, i.e., much before Finance Act, 2021 was promulgated on 1-4-2021-Application shall be treated as pending applications to be considered by Interim Board-Direction was issued to consider application. [S. 119(2)(b), 153A, 245C(1), 245C(5) Art. 226]

S. 245C : Settlement Commission-Settlement of cases-Conditions-Abolition of Settlement Commission-Interim Board Settlement Commission inoperative from 1-2-2021-Application on 17-3-202, i.e., prior to date when assent of President of India had been received for Finance Act, 2021-Application was restored to file of Settlement Commission. [S. 24B. 245C(1), 245(5) Art. 226]

S. 244A : Refunds-Interest on refunds-Compensation of acquisition of agricultural land-Assessee neither made aware of deduction of tax at source nor issued form 16A by deductor-Delay in application for refund under circumstances beyond control of assessee Assessee-Entitled to interest on refund-SLP delay of 457 days-SLP dismissed on account of delay as well as on merits. [S.194LA, Art. 136]

S. 220 : Collection and recovery-Assessee deemed in default-CIT(A) allowed the appeal-Tribunal allowed the appeal of the revenue-Fresh notice of demand-Liability to interest commences from expiry of one month from second notice-CBDT-Circulars issued by Central Board not binding upon court-Circular No. 334, dated 3-4-1982(1982) 135 ITR 10 (St) [S. 119, 156,220(2) 254 (1), Art. 226]

S. 197 : Deduction at source-Certificate for lower rate-Software license agreement-Order set aside with directions to decide the application in accordance with the order of Dispute Resolution Panel and the order of Supreme Court-DTAA-India-USA [Art. 7, Art 226]