S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revision-No finding that assessment order was prejudicial to revenue-Not given adequate opportunity to the assessee to be heard-Revision order is quashed-Revenue is directed to pay the cost of Rs.10000 which shall be deposited with Allahabad Legal Service committee. [Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains or business income-Investment in stock in trade-Deemed dividend-Capital contribution by company-Not loan or advance-Commercial transaction-Order of Tribunal quashing the revision is affirmed.[S. 2(22)(e), 28(i), 45]

S. 260A : Appeal-High Court-Delay in filing appeal of 3270 days-Time required to clear certain objections & some time was required to arrange certain documents-Appeal dismissed.[S.153A]

S. 260A : Appeal-High Court-Substantial question of law- Appeal admitted by Court formulating ten questions of law- At time of final hearing Court dismissing appeal holding no question of law arises- Order of High Court set aside and matter remanded for disposal b Court on merits. [Art. 136]

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-Sales tax subsidy-Shown taxable in the return-CIT(A) is justified admitting the additional ground-Order of Tribunal is affirmed.[S.4, 139(5), 254((1)]

S. 260A : Appeal-High Court-Delay of 2139 days-Lacked bona fides- Order of High Court refusing to condonation of delay-SLP dismissed. [Art. 136]

S. 245D : Settlement Commission-Settlement of cases-Procedure-Assessee paid taxes on own calculations-Compliance of the provisions of section 245D (2D)-No abatement-Matter remanded to Interim Board. [S. 245AA 245C,245D(2D), 245HA(1)(ii), Art.226]

S. 245C : Settlement Commission-Settlement of cases-Pending cases-Constitution validity of an amendment to Section 245A discontinuing operation Settlement Commission w.e.f. 01-02-2021 also challenged the validity of Circular / Order F.No. 299/22/2021-DIR(INV.III) dtd. 28-09-2021-Last date mentioned in circular should read as 31-3-2021-Orders rejecting applications on ground that no case pending as on 31-1-20021 set a side-Applications to be deemed pending for consideration by Interim Board-Abolition of Settlement Commission-Jurisdiction of court-Right to seek resolution through Settlement Commission conferred by statute-Within policy realm of State to take away remedy or benevolence given-Court cannot substitute its opinion to abolition of Settlement Commission. [S. 245A, 245D, 245M, Art. 226]

S. 245C : Settlement Commission-Settlement of cases-Conditions-Validity of amendments to Act abolishing Settlement Commission and Circular issued by CBDT stipulating final date for filing application before Settlement Commission-Dismissal of writ petition by a single judge at admission stage is held to be not proper-Respondents are directed to file affidavits for consideration of legal aspects-Limitation-Search cases-Notices are stayed till the disposal of appeals. [S. 132, 153A, 245D, Art. 226]

S. 237 : Refunds-Central Board of Direct Taxes-Refund of tax deduction at source-Less than Rs.5 lakhs-Condonation of delay-Application seeking condonation of delay in filing the revised return-Refund in revised return is based on Form 16A for TDS on rental income, and the claim was not supplementary as per Instruction No. 12 dated 30-10-2003-Application for condonation of delay in filing the revised return is directed to be allowed-Entitle to refund which is within prescribed upper limit. [S.119(2)(b),139(4), Art. 226]