S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record-Application for recalling Tribunal’s order-No rectifiable mistake apparent on the record.[Art. 136]

S. 245D : Settlement Commission-Settlement of cases-Full and true disclosure-Power-Grant immunity from prosecution and penalty-Application rejected due to lack of true and full disclosure-SLP of assessee is dismissed. [S. 245C, 245H, Art. 136]

S. 220 : Collection and recovery-Assessee deemed in default –Stay of recovery-SLP of assessee is disposed of by reserving liberty to assessee to file a review petition before Division Bench of High Court and till initial consideration of review petition for any interim or final order, there would be stay of directions. [Art. 136]

S. 192 : Deduction at source-Salary-Diversion of income by overriding title – Salary of teachers of Christian Institutions paid by State Government – Teachers paying their entire salaries to Church – Salaries not diverted at source by overriding title – State Government is bound to deduct tax at source on salaries-Central Board of Direct Taxes – Circulars -Circulars issued before independence of India – Subsequent circulars overriding earlier circular – Exemption granted under old circular is not binding on Revenue-SLP of assessee is dismissed.[S. 4, 5, 15, 192A up to 194LBB, Art. 136]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction note pertained to non-searched entity and material which was alluded to pertained to assessment year 2019-20 only-Notice pertaining to AYs 2014-15, 2015-16, 2016-17, 2017-18, 2018-19 and 2020-21 is quashed and set aside by High Court-SLP of Revenue is dismissed.[S. 132, Art.136]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Time limit for notice-Notice issued for assessment year 2013-14, under old regime after expiry of six years-SLP is disposed of in terms of judgment of Supreme Court in Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70 (SC).[[S. 147, 148, 148A(b), 148A(d), 149, Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S.3, Art. 136]

S 90: Double taxation relief – Capital gains – Exempt income – Set-off of losses – Carry-forward allowed – No set-off of capital losses against exempt gains permitted- Carry-forward of losses for future years is allowed, subject to that the set-off must be applied only to income which is taxable in India -DTAA -India – Mauritius . [S. 70,74(1),90(2), Art. 4, 13(3B) ,13(4)]

S. 132B : Application of seized or requisitioned assets –Search and Seizure – Jewellery – Release of seized assets – Strictures – Accountability – Jewellery seized in the year 2005 – Not released to the assessee even after 25 years – Loss of seized jewellery from the Bank locker – Legal heir entitled to return of jewellery – Income tax department and Bank held liable to compensate – Interim relief granted- The Court emphasized the importance of fair tax governance and proper security measures in Nationalized Banks and Scheduled the matter for further hearing on February 11- Copy of the order is forwarded to the Chairman CBDT and the Chairperson and Managing Director of Bank of Maharashtra . [S. 132, Art. 226]

S. 151 : Reassessment – Sanction for issue of notice – Notice issued after three years from the end of the relevant assessment year – Principal Chief Commissioner – Approval obtained from Principal Commissioner instead of Principal Chief Commissioner – Reassessment notice and consequential order is quashed and set aside . [S. 56(2)(vii)(b), 144B, 147, 148 ,151(ii) ]

S. 148: Reassessment –Notice – – Non existing company -Merger of companies – Notice served on non -– existing company or entity despite the respondents’ knowledge of its non-existence – Notice is quashed and set aside . [S. 2(31), 292B, 148A, 151, 292B, Art. 226 ]