S. 12AA : Procedure for registration-Trust or institution-Rejection of registration after prescribed period of six months-Cannot result in deemed grant of registration-Tribunal not justified in granting assessee deemed registration. [S. 12A, 12AA(2)(iii), 260A]

S. 10(26AAA) : Income of Sikkimese-Individual-Income not included-Definition of ‘Sikkimese’ as amended by Finance Act, 2023-Definition limited to Income-tax Act only-Does not affect rights under Article 371F(k) of Constitution of India-PIL dismissed. [Art. 226, 371F(k)]

S. 10(26AAA): Income of Sikkimese – Individual-Income not included-Definition of ‘Sikkimese’ as amended by Finance Act, 2023-Definition limited to Income-tax Act only-Does not affect rights under Article 371F(k) of Constitution of India-PIL dismissed-SLP dismissed.[Art. 136, 371F(k)]

S.10(26) : Schedule Tribes-Member of Scheduled Tribe community of Rajasthan, was posted at Agartala, Tripura, a specified area-Entitled to benefits of exemption from income tax flowing from provisions of section 10(26) of the Act. [Art. 226]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-HSBC (Suisse) accounts-Unauthenticated DTAA-sourced information from France about alleged Swiss bank accounts, coupled with no incriminating material found in search and no corroboration, cannot sustain prosecution.[S.132, 132(4), 276D, 277, 278E]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash credits-Adequate enquiry by Assessing Officer-Lack of enquiry-General observation by CIT-High Court affirmed the order of Tribunal-SLP of revenue dismissed.[S. 68, 143(3),153A, Art. 136]

S. 254(1) : Appellate Tribunal-Powers-Settlement Commission-CIT(A) did not adjudicate issue on merits and dismissed the appeal-Tribunal remanded matter back to CIT(A) for consideration-High Court affirmed the order of the Tribunal-SLP of revenue dismissed.[S. 245D(4), 245HA, 246A, 250, Art. 136]

S. 244A: Refund-Interest on refund-Delay in filing return condoned-Assessee not at fault-Deductor failed to intimate TDS and issue Form 16A-Interest payable from date of TDS deposit till date of refund-Delay of 471 days-SLP of revenue dismissed on account of delay as well as on merits. [S. 119(2)(b), 194LA, Rule 13 of IT Rules, Art. 136]

S. 244A: Refund-Interest on refund-Delay in filing return condoned-Assessee not at fault for non-claim of refund-Deductor failed to inform TDS and issue Form 16A-Interest payable from date of TDS deposit till the date of refund-Delay of 457 days-SLP dismissed on account of delay as well as on merits. [S.119(2)(b), 194LA, Rule 13 of IT Rules, Art. 136]

S. 206C : Collection at source-Trading-Forest produce-Illegal mining-TCS applies only to payments by lease/license/contract-holders and cannot extend to compounding fees/fines from illegal miners-Order of Tribunal set aside. [S.133A, 206(IC), MMDR Act, 23A(1), R.71(5)]