S. 4 : Charge of income-tax-Transfer of rights-Value of any benefit or perquisites-Business income-Transfer is genuine-Set off credit-No evidence-Deletion of addition is valid. [S. 28(iv)]

S. 2(22)(e) : Deemed dividend-Advances to directors-Joint owner of property-Advance to be adjusted for sale consideration-Matter remanded to the Tribunal for reconsideration. [S. 254(1)]

S. 2(22)(e) : Deemed dividend-Unsecured loan from company-Partner of firm shareholder-Dividend is taxable in hands of Individual and not in the name of firm-Remand by the Tribunal is set aside. [S. 254(1)]

Black Money (Undisclosed Foreign Income & Assets) and Imposition of Tax Act, 2015 .

S.50: Punishment for failure to furnish return of income –Information about an asset – located outside India – Punishment for wilful attempt to evade tax – Foreign asset – Prosecution – Pendency of appeal before CIT(A) – Criminal provision of sections 50 and 51 could not have a retrospective effect – Stay of criminal proceedings- Notice was issued to Advocate General regarding petition filed by petitioner and stay granted earlier to be extended till next date of hearing . [ S. 51 , Income -tax Act , 1961 , S.276C , Art . 226 ]

Black Money (Undisclosed Foreign Income & Assets) and Imposition of Tax Act, 2015 .

S. 41 :Penalty in relation to undisclosed foreign income and asset – Penalty for failure to furnish in return of income, an information or furnish inaccurate particulars about an asset (including financial interest in any entity) located outside India -Pendency of appeal – Directed to hear the assessee and pass the order after considering the submission of the assessee . [ S. 15, 42 , 43 , Art. 226 ]

S. 40(a)(i) : Amounts not deductible – Deduction at source -Non-resident – Reimbursement of mobilisation and demobilisation costs to a foreign company – Subsequently the foreign company was held liable to tax in India – Not liable to deduct tax at source – Cannot be treated as assessee -in -default – DTAA -India – Netherlands .[ S. 9(1)(vi), 195, Art. 12, Art. 136 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Where the alleged escaped income is below the prescribed monetary threshold of Rs.50 lakhs, the period of limitation as stipulated under Clause (a) of Sub-section (1) of Section 149 of the 1961 Act would be applicable- The period prescribed under the said Clause is three (03) years from the end of the relevant assessment year – Reopening notices dated 30.6.2021 and 28.06.2021 issued were held to be barred by limitation . [ S. 148 , 148A(b) , 148A(d), 149(1))(a) , Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3 , Art .142 , 226 ]

S. 250: Appeals – Commissioner of ( Appeals ) – National Faceless Appeal Centre ( NFAC) -Pendency of appeals – Delay in disposal of appeals – Honourable court has directed the government to take appropriate measures to fill up all vacant posts and also increase the sanctioned strength of Commissioner (Appeals) so as to achieve the target at least 570 of such posts . [S. 246, 250(6A), Art . 226 ]