S. 251 : Appeal-Commissioner (Appeals)-Powers-Direction to initiate penalty proceedings-No proceedings were pending before CIT(A)-Direction to initiate penalty proceedings after culmination of appellate proceedings are without jurisdiction.[ S. 154, 250, 270A]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Directions-Reassessment-Limitation-Reassessment on the basis of observation of CIT(A) is not justified-Reassessment is quashed as time barred.[ S. 147, 148, 149(1)(b), 150]

S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-Pendency of rectification application under section 154-Delay of six years-Not condoned-Direction of CIT(A) to dispose the rectification application within six months is affirmed.[ S.154, 254(1)]

S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-Delay of 3177 days-No reasonable cause-Dismissal of the appeal is held to be valid.[ S.246A, 254(1)]

S. 249 : Appeal-Commissioner (Appeals)-Form of appeal and limitation-Delay reasonable cause-Delay of 162 days-Affidavit is filed-Delay is condoned and the matter is remanded to the file of CIT(A) to decide on merits.[ S.249(3), 254(1)]

S. 246A : Appeal-Commissioner (Appeals)-Appealable orders-Defective return-Treating the return as invalid-Not appealable-Appeal is not maintainable. [S. 44AB, 139(9), 246A(1)(a)]

S. 244A : Refunds-Interest on refunds-Rectification order-Department should calculate the interest component while passing the order under section 154 of the Act. [ S. 154, 244(IA)]

S. 201 : Deduction at source-Failure to deduct or pay-Failure to deduct tax at source-Interest-Form No 15G, Form No 15H-Not verified by the Assessing Officer-Matter remanded for to the Assessing Officer for fresh adjudication. [ S.194A, 201(1), Form No 15G, Form No 15H]

S. 194J : Deduction at source-Fees for professional or technical services-Foreign agents-No business connection-Not performed any job /operation in India-Not liable to deduct tax at source-OECD Model convention-art.12-Reimbursement of expenses-Not chargeable to tax-Not liable to deduct tax at source. [ S. 5(2)(b), 9(1)(vii), Explanation, 195, 201(1), 201(IA), 204]

S. 164 : Representative assessees-Charge of tax-Beneficiaries unknown-Violation of section 13-Trust has to be taxed at maximum marginal rate under section. 164 (2) on its income. [ S.11, 13(1)(c), 13(2), 164 (2)]