S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Participated in the proceedings by filing return and responding to the notice – Writ is not maintainable [s. 147, 148, 148A(b), Art , 226 ]

S. 144B : Faceless Assessment – Violation of principle of natural justice – Show cause notice – Only two day’s time to file response – Violation of Circular dated 3-8 -2022 – Minimum period of seven days should be provided – Order was set aside [ S. 144(6)(vii),Art, 226 ]

S.37(1): Business expenditure – Marked -to -Market loss – Loss arising on reinstatement of the forward cover purchase contracts – Not speculative -CBDT Instructions and circulars which are contrary to law are not binding – Allowable as revenue expenditure . [ S. 43(5), 73 ]

.37(1): Business expenditure – Corporate Social Responsibility( CSR)- Explanation 2 was inserted in section 37 by Finance (No.2) Act , 2004 , w.e.f. Ist April , 2015 – Apply in relation to the assessment year 2015 -16 and subsequent years – Expenditure allowable as deduction .

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Compounding of offence-Past conviction for default in depositing of TDS were not disclosed-Order of conviction was under challenge before Supreme Court and stayed-Order of rejection was held to be valid-Untill pending conviction orders with respect to earlier years were set aside. [S. 276B, 278B, Art. 226]

S. 276CC : Offences and prosecutions-Failure to furnish return of income-Search-Delay of 72 days in filing of return-Failure to provide copies of statements-No evasion of tax-Lunching of prosecution was quashed. [S. 132, 153A, 279]

S. 276CC : Offences and prosecutions-Failure to furnish return of income-Return was filed within extended time-Refund was granted-Criminal miscellaneous was quashed. [S. 139(1), 139(4)]

S. 271D : Penalty-Takes or accepts any loan or deposit-Loan from sister concerns-Payments to labour charges-Reasonable cause-Deletion of penalty is justified. [S. 269SS]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Accomodation entries-Information from Maharastra Sales tax Department-Order passed without making any inquiry or verification-Bogus purchase bills-Offered 2% of bogus purchases-Revision to assess the entire purchases as disallowable is held to be justified-Order of Tribunal set aside. [S. 69C, 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Depreciation-Scientific research-Two views possible-Assessing Officer following the order of jurisdictional High Court-Order cannot be held to be erroneous. [S. 35(2)(iv)]