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]

S. 154 : Rectification of mistake-Mistake apparent from the record-Refund-Short grant of credit of tax deducted at source-Brought forward loss and unabsorbed depreciation- Direction issued to decide the application within eight weeks’ time.[Art. 226]

S. 153C : Assessment-Income of any other person-Search-Statement on which reliance has been placed for issuance of notice under section 153C shall be provided to the assesse-Order is set a side with the direction. [Art. 226]

S. 153C : Assessment-Income of any other person-Search-Not discharged the burden of having agricultural income-Addition as undisclosed income is justified-Order of High Court is affirmed. [s. 260A, Art. 136]

S. 153A: Assessment-Search-No incriminating material-Completed/unabated assessments-Order of Tribunal deleting the addition is affirmed.[S.132, 132A, 147, 148]

S. 149 : Reassessment-Time limit for notice-A notice issued within the statutory limitations, considering the extensions and exclusions per the proviso to the section, is deemed timely and valid.[S. 148, 148A(b), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-No procedural irregularities or lack of opportunity of being heard-Order containing detailed reasoning- Alternative remedy-Writ petition is dismissed.[S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-No violation of principles of natural justice.-Writ petition is dismissed. [S. 148, 148A(b), 148A(d), Art.226]