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-SLP of Revenue is dismissed. [S. 245A, 245D, 245M, Art. 136]

S. 226 : Collection and recovery-Modes of recovery-Recovery of tax-Appellate Tribunal-Interim order-Conditional stay of demand of tax and interest on demand-Exercise of discretion by Tribunal neither perverse nor illegal and hence not interfered with-On facts recovery is not protective in nature. [S. 144C, 254(1),254(2A), Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Recovery of tax-Attachment and sale of immovable property-Limitation-Assessment order was passed in final year ending on 31-3-2010-Attachment of property on 20-12-2018 and proclamation of sale on 27-3-2019-Barred by limitation [S. 245-I, Chapter XVII of the Income-tax Act, 1961, Second Schedule, R. 68B, Art. 226]

S. 225 : Collection and recovery-Stay of proceedings-Capital gains-Full value of consideration-Stamp valuation Assessee has right to get capital asset valued by Departmental Valuation Officer-Granted interim stay of coercive action pending disposal of the statutory appeal. [S. 45,50C, 56(2)(x), 143(3), 250, Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Recovery of tax-Stay-Zoos and Parks Authority of State-Pendency of appeal before CIT(A)-Stay is granted until disposal of appeals on condition of depositing part of outstanding demand.[S 11, 156, 220(6), Art. 226]

S. 153D : Assessment-Search-Approval-Mechanical approval-ACIT granted approval without noticing discrepancy in assessment order or search material-Mechanical approval without application of mind would be invalid in eyes of law-No substantial question. of law. [S.132,153A, 260A]

S. 153D : Assessment-Search-Approval-Mechanical approval-ACIT granted approval without noticing discrepancy in assessment order or search material-Mechanical approval without application of mind would be invalid in eyes of law. [S.132,153A Art. 136]

S. 153C : Assessment-Income of any other person-Search-Limitation-Block period Ten-year block period-Notice u/s 148 dated 31-3-2023-Notice for Assessment year 2013-14 is not sustainable. [S. 132, 147, 148, 149(1) 153A, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Death of assessee-Intimation of death to Department-Order and consequent notice issued in name of deceased assessee-Notice is void and invalid.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Non-Resident-Agreement bifurcating licence fee between live feed and recorded content-Receipt not Liable to tax in India-Notices and order is quashed.[S. 147, 148, 148A(b) 148A(d), Art. 226]