S. 32 : Depreciation-Block of assets-Hotel-Temporary closure-Put to use less than 180 days-Second proviso-Acquired earlier years-Second and third proviso is not applicable-Depreciation is allowable.[S. 32(1), 260A]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Following the ratio in UOI v. Rajeev Bansal [2024] 167 taxmann.com 70 (SC) the time limit for issue of notice was extended only up to 30 -6 -2021 – Assessment year 2013 -14 the notice was issued on 29 -7 -2022 , for the Assessment year 2014 -15 the notice was issued on 31 -7 -2022 and for the Assessment year 2015 -16 the notice was issued on 28 -7 -2022 -All the notices are barred by limitation – Reassessment is quashed . [ S. 147, 148 , 148A(b), 148A(d) , 149(1), TOLA, S.2, 3 ]

Income Declaration Scheme, 2016.
S. 183: Payment of tax-Adjustment of advance tax and self assessment tax-Matter is remanded with the direction for redo the exercise after examining the accounts of the assessee for AY. 2012-13 and ascertain whether the assessee has indeed made a correct declaration of income. [Art. 226]

Direct Tax Vivad Se Vishwas Act, 2020.
S. 4 : Pendency of appeal-Order passed by Tribunal-Not served on the assessee-Appeal cannot be treated as pending-Rejection of application is held to be justified.[S. 2(1)(a), R.9 Form Nos. 1, 2, Art.226]

S. 264 : Commissioner-Revision of other orders-Rejection application under section 154-Intimation-Remuneration to partners-Expenses claimed-Directed to file an appeal-Writ petition is dismissed-Delay in filing the appeal or Revision against the intimation is directed to be condoned. [S. 143(1), 154, 246A, Art. 226]

S. 261 : Appeal-Supreme Court-Interpretation of taxing statue-Binding precedent-Review petition is pending-Judgment of the three Judge Bench is holding the field-Judgment has to be followed-Non-Resident-Computer software supplier-Not royalty-Not taxable in India-DTAA-India-USA.[S. 9(1)(vii), 90, Art. 12, Code of Civil Procedure, 1908, Order XLVII, R 1]

S. 205 : Deduction at source-Bar against direct demand-Tax deducted at source-What the Revenue cannot do directly, it is impermissible for it to reach the same end indirectly-Revenue is directed to refund-Mistake apparent-Review petition is dismissed.[S.260A, Form No 16A]

S. 170A : Effect of order of Tribunal or Court in respect of business reorganisation-Assessment-Effect of order of Tribunal or Court in respect of business reorganisation-Amalgamation-Consolidated return-Assessment order within two days of reply by making 59 additions-Assessment order is quashed and set aside. [S. 148, 143(3), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Earlier notice under S 148 was quashed-have been quashed-Not complied with the amended provision of S.148A inserted by the Finance Act. 2021-Revenue had to proceed from the stage of S. 148A(b), on dispensation of inquiry as directed by the Supreme Court in UOI v. Ashish Agarwal (2022) 326 CTR 473 / 213 DTR 217 (SC)-Assessee had right to reply to the show-cause, consideration of which may have led to an order passed under S. 148A(d), for issuance of notice under S. 148 subsequent thereto-Notices and assessment order are quashed. [S. 148, 148A(b),148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Violation of principle of natural justice-Non-speaking order-No procedural irregularities-Writ petition is dismissed.[S. 148, 148A(b), 148A(d), Art. 226]