S. 271AAA : Penalty-Search initiated on or after 1st June, 2007-Issued notice under wrong section-Non-striking off of the irrelevant limb-Levy of penalty is bad in law.[S.153A, 271(1)(c)]

S. 271(1)(c): Penalty-Concealment-Notice-AO had not struck off the inapplicable portion as to whether the levy of penalty was for concealment of income or for furnishing of inaccurate particulars of income-Penalty is not valid.[S.274]

S. 271(1)(c): Penalty-Concealment-The assessee has neither concealed the particulars of the income nor furnished such facts which lead to the furnishing of inaccurate particulars.

S.263: Commissioner-Revision of orders prejudicial to revenue-Not for corrections, errors & mistake-No order in existence.[S.271(1)(c), 271AAB(IA)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Duly examined matter on mere surmise of human probability. [S. 142(1), 143(2), 143(3)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Assessment order which is nullity in law-Cannot be revised. [S.132A, 143(3)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Principal commissioner is not justified in initiating revision proceedings when proceedings have already declared under the Direct Tax Vivad Se Vishwas Scheme. [Direct Tax Vivad Se Vishwas Act, 2020, S. 8]

S. 263: Commissioner-Revision of orders prejudicial to revenue-commissioner taking view explanation offered by the assessee to assessing officer not satisfactory and assessing officer had failed to conduct further enquiries, revision based on audit objection is invalid. [S. 68, 69, 69A, 69B, 69C, 69D, 115BBE]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-AO allowed deduction u/s 35(2AB) after verifying all the necessary documents and certificates-Neither the AO nor the PCIT has power to question the approval granted by the DSIR. [S. 35(2AB), 143(3)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-No detailed inquiry or verification by PCIT-Failure to point out error in assessment order-Order is quashed. [S.35(2AB), 143(3)]