S. 264 : Commissioner-Revision of other orders-Delay of two years-Pedantic-Genuine hardship cannot be restricted to severe financial crises is only unwarranted-The Authorities have to do substantial justice-Directed to condone the delay and decide the matter on merits-Rectification of mistake-Duty of Assessing Officer-Pendency of rectification application for six years-The Assessing Officer duty bound to pass order expeditiously-The Hon Court directed to place Copy of this order to the Chairman of CBDT, so that suitable actions are taken to comply with the directions given by this court. [S. 44AB, 80IC, 119(2)(b), 143(1), 154, Art. 226, Form No 10CCB]

S. 260A : Appeal-High Court-Delay of three years -Not explained sufficient cause in delay in filing an appeal-The lack of sincerity, or rather complete absence thereof on the part of the Revenue in this case was glaringly conspicuous by its having not even filed an application seeking condonation of this colossal delay of about three years in filing these appeals-Delay is not condoned.[S.260A(1) 260A(2)

S. 245D : Settlement Commission-Settlement of cases-Procedure-Application-Settlement Commission empowered to examine and adjudicate all aspects arising from application and accord full and complete closure to all disputes-Entitled to exercise all powers that are otherwise vested in Income-Tax Authority-Explaining transaction and surrendering disputed receipt-Cannot be treated as non-disclosure in application-Voluntary surrender accepted-Procedure adopted by Settlement Commission neither incorrect nor erroneous. [S. 245C, 245D(4), 245E, 245F, 245I, Art. 226]

S.234E: Fee-Default in furnishing the statements-Deduction of tax at source-Delay in filing statement of tax deducted at source-late fee-Position prior to 1-6-2015-Amendment of section200A with effect from 1-6-2015-Late fee could be charged in respect of delay prior to amendment.[S.200A(1)(c), 206C(3), Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Garnishee proceedings-Appeal-High Court-Stay of recovery pending appeal-Buyback of Shares-Interim stay of recovery proceedings granted on conditions of deposit of cash and property for remaining dues with department.[S. 2(22), 46A, 115-O, 220 (6), 260A, Art. 226]

S. 197 : Deduction at source-Certificate for lower rate-Mere assertion that income could not be estimated cannot be ground for rejection of application for certificate. [R.28AA, Art. 226]

S. 153C : Assessment-Income of any other person-Search-Block Assessment-Satisfaction note-Block period-Seized material must pertain to relevant assessment year-Bearing-Notices issued in absence of incriminating material based on non-speaking satisfaction notes unsustainable-Satisfaction notes in these petitions had alluded to incriminating material having been recovered for the assessment years 2013-14 and 2014-15, respectively, and the materials that were correlatable had been specifically identified. All other contentions of parties could be raised in the ongoing proceedings. [S. 132, 153A 158BB, Art. 226 ]

S. 149 : Reassessment-Time limit for notice-Notices issued under unamended provision after 1-4-2021 for assessment year 2013-14-Notice is not barred by limitation.[S. 147, 148, Art. 226]

S. 149 : Reassessment-Time limit for notice-Finance Act, 2021-Search conducted in June, 2022-Relevant assessment year-Notice of reassessment on 31-3-2023 for Assessment Year 2013-14 is valid. [S. 149 153A, 153C, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Assessee must be given opportunity to be heard-Notice and order disposing the objection is quashed and set aside.[S. 148, 148A(b), 148A(d),Art. 226]