S. 253 : Appellate Tribunal-Monetary limits-Penalty-Exception provided in para 10(e) of Circular No. 17 of 2019 (2019) 426 ITR 106 (St), applicable only for quantum proceedings and cannot be applicable for penalty proceedings – Appeal is not maintainable. [S. 254(1), 271(1)(c)]

S. 251 : Appeal-Commissioner (Appeals)-Power of enhancement-No jurisdiction to travel beyond record-Appeal against cash credits-Enhancement cannot be made for making estimate commission of 2 Per Cent of commission. [S. 68, 251(1)(a)]

S. 153C : Assessment-Income of any other person-Search-Opportunity of cross examination. Was not given-Addition is not valid-Order passed u/s. 143(3) is bad in law-Order ought to have been passed u/s. 153C. [S. 132, 143(3), 153A]

S. 153A : Assessment-Search or requisition-No incriminating material was found-Addition cannot be made merely on the basis of post dated cheques without any corroborative evidence. [S. 132]

S. 151 : Reassessment-Sanction for issue of notice-Additional ground was admitted-Delay in filing the appeal was condoned-Sanction was mechanical, without application of mind-Order of reassessment was quashed. [S. 147,148, 151, 253, 254(1)]

S. 148 : Reassessment-Notice-Recording of reason stating that the assessee failed to file return of income-Contradictory to facts on record-Mechanical sanction-Notice u/s. 143 (2) was issued on same day on which the assessee appeared in response to notice u/s 148-Order was quashed. [S. 143 (2) 143(3), 147, 151]

S. 148 : Reassessment-Notice-Recording of reason stating that the assessee failed to file return of income-Contradictory to facts on record-Order was quashed. [S. 143(3), 147]

S. 148 : Reassessment-Notice-Notice was not served-Approval granted was of mechanical manner-Legal issue-Additional ground was admitted-Reassessment proceedings is quashed. [S. 144, 147, 254(1), 282(1), Civil Procedure Code,1908, Order V rule 12, Order III rule 6]

S. 147 : Reassessment-Jurisdiction-Notice issued by one Officer-Reassessment order was passed by another circle-No order by Competent Authority transferring case-Order was liable to be quashed. [S. 127(2), 144, 148]

S. 147 : Reassessment-Carbon credit-Capital receipt-Reassessment notice to contrary decision of High Court-Held to be in valid. [S. 4, 148]