S. 220 : Collection and recovery-Assessee deemed in default-Recovery of tax-Attachment and sale of immovable property-contents of proclamation-Reserve price-Auction of property-The auction notice clearly stated that the terms and conditions of the proposed auction could be downloaded from the website of the Income-tax Department or collected from the office of the Tax Recovery Officer-No violation-Order of attachment is valid. [S. 226, Rule 53 of Second Schedule Art, 226]

S. 197 : Deduction at source-Certificate for lower rate-Pendency of rectification application-Directed the Assessing Officer to expedite decision on rectification application and grant refund. [S. 154, 234, Art. 226]

S. 153A : Assessment-Search or requisition-Notice under Section 143(2) is not necessary. [S. 132, 143(2)]

S. 153A : Assessment-Search or requisition-No mandatory requirement that assessment or reassessment should be based only on basis of incriminating material found during search-Other incriminating material can be relied on-Order of Tribunal set aside and directed to decide on merits. [S. 69, 132]

S. 153A: Assessment-Search or requisition-Assessments Completed and final as on date of search-No incriminating material found during search-Order of Tribunal affirmed-No substantial question of law. [S. 68, 69, 132,143(1), 143(3), 260A]

S. 153A : Assessment-Search or requisition-Notice-Search and seizure-No incriminating material found during search-Time for issue of notice under section 143(2) expiring on date of search-Additions cannot be made. [S. 132, 143(2)]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Grant of minimum of seven days’ time is mandatory-Failure to grant causing prejudice-Order and subsequent notice for reopening of assessment was quashed. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Rejection of rectification application-Violation of principle of natural justice-Notice and assessment order was quashed-Cost was imposed on the Revenue-The respondents were directed to pay cost of Rs. 50,000 to the assessee. [S. 147, 148, 148A(b), 148A(d), 154, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Failure to consider the reply of assessee-Verification-Order and subsequent notice for reopening of assessment was quashed-Matter was remanded to pass a fresh reasoned order. [S. 147, 148A(b), 148A(c), 148A(d), Form, 26AS, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-No material or report produced which was basis for information to reopen assessment-Order and notice quashed and set aside-Department given liberty to furnish additional materials in support of allegations made in show-cause notice and proceed in accordance with law. [S. 147, 148, 148A(b), 148A(d), Art. 226]