S. 271(1)(c) : Penalty – Concealment – Capital gains – Higher valuation as per S.50C – Merely because higher valuation – Levy of penalty is not valid. [S. 45, 50C, 245C, 245D, Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue -Accrual – Accounting – Once an order become final and stood quashed-Subsequent order is not valid.[S. 143(3),145(1), 260A.]

S. 261 : Appeal-Supreme Court – Condonation of delay of 484 days – Explanation was not satisfactory – SLP of Revenue is dismissed. [Art. 136]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record -Followed Orissa High Court-Not following the Jurisdictional High Court-Mistake apparent on record – Order of Tribunal is quashed – Matter is remanded back to the Tribunal.[Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Adjustment of more than 20 per cent against demand-Credit for TDS and TCS must be considered – Excess amount collected is directed to be refunded. [S. 239, 240 Art. 226]

S. 153 : Assessment – Limitation – Remand by Tribunal – Order received by CIT (Judicial) on 31 st Jan., 2019-Adjustment of refund-Order was passed on 13th Feb., 2023-Order is set aside-Respondents are directed to re-compute the refund payable to the assessee along with statutory interest. [S. 153(3), 237, 240 244A, 254(1), Art. 226]

S. 153 : Assessment – Reassessment – Limitation -Order was passed on 28th Dec., 2006, the same was communicated to the Authorized Representative of the assessee only on 5th Jan., 2007 – Order is without jurisdiction-Order is quashed and set aside.[S. 147, 148, 153(2), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation -Six days time was granted for giving reply as against the statutory minimum seven days – Natural justice-Limitation of three years-Opportunity of being heard-Information has been found recorded in the electronic books of accounts of a third party OMX Ltd-Writ petition is dismissed. [S. 148, 148A(b), 148A(d), 149(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Period of 10 years-Deposits in bank accounts-Assets – Foreign contribution-Writ petition is dismissed. [S. 148, 148A(b), 148A(d), 149, Art. 226]

S. 147 : Reassessment –With in four years-Gift of shares – Transfer of capital asset-Neither S. 50CA or S. 50D were applicable – No tangible material-Reassessment notice and order disposing the objection is quashed.[S. 45, 47, 48, 50CA, 50D, 148, Art. 226]