S. 220 : Collection and recovery-Assessee deemed in default-Stay-Paid 20 percent of disputed demand-Assessee cannot be held to be assessee deemed to be in default-Adjustment of refund without giving an intimation u/s. 245 of the Act is held to be bad in law-Directed to refund with accumulated interest. [S. 245, Art. 226]

S. 215 : Interest payable by assessee-Advance tax short of assessed tax-Fresh assessment made by Assessing Officer giving effect to Commissioner’s revision order constitute a regular assessment-Entitle to waiver of interest only to extent stated in order under Rule 40(1). [S. 139(8), 215(4), 215(6), 263]

S. 153A : Assessment-Search or requisition-No incriminating material was produced nor stated in the notice-Notice was quashed as the respondent has failed to specify the seized documents. [S. 132, 132A, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-After the expiry of four years-Approval and reasons recorded of same date-Sanction was not properly obtained-Reassessment notice was quashed. [S. 147, 148, Art. 226]

S. 151 : Reassessment-Sanction for issue of notice-Reason recorded was furnished of other assessee-Two further reasons were signed by successor officer and no fresh approval was obtained-Reassessment notice was quashed. [S. 147, 148, Art. 226]

S. 151 : Reassessment-Sanction-Recorded reasons are not correct-Date of return was filed on 25th November 2014, where as in the recorded reasons it was stated as 27th October, 2016-Assessee holds shares 0.01%, i.e. 10 shares in itself-How can a company hold its own shares-Reassessment notice was quashed. [S. 147, 148, Art. 226]

S. 151 : Reassessment-Sanction-After the expiry of four years-Sanction was given mechanically-Without application of mind-Reason recorded stated that the assessment was completed u/s 143(1), whereas the assessment was u/s. 143(3)-Business of jewellery-Reason stated that failure to disclose salary-Reassessment notice was quashed. [S. 147, 148, Art. 226]

S. 151 : Reassessment-Sanction-After the expiry of four years-Sanction was granted by Addl. CIT and not PCIT-Reference contained another entity-Non application of mind-Order was quashed and set a side. [S. 148, 151, Art. 226]

S. 150 : Assessment-Order on appeal-Time limit for reopening of assessment-Deemed dividend-Section 150 will apply only to reopening assessment to give effect to finding or direction in appellate orders of CIT(A) and not to appellate orders of any High Court u/s. 260A. [S. 2(22)(e), 116, 147, 148, 149, Art. 226]

S. 148 : Reassessment-Notice-Notice was issued prior approval of Additional Commissioner-Notice was quashed. [S. 147, 151(2), Art. 226]