S.147: Reassessment – After the expiry of four years – Short term capital loss – Long term capital gains – No specific allegation in the reopening notice to disclose any material facts- Reasons for reopening were based entirely on records already available during the original assessment- Reopening notice, order disposing the objection order, reassessment order, and the demand notice is quashed and held as invalid.[ S. 45 , 148 Art. 226 ]

S. 68 : Cash credits – Sale of shares –Explained the nature and source – Investment and the transaction was part of a larger acquisition by KKR Group – Order of CIT(A) deleting the addition is affirmed .[S. 115BBE , 133(6) ]

S.54F : Capital gains- Investment in a residential house -Joint property purchase with wife –Joint transfer for consideration- s The wife’s inclusion in the property title was deemed nominal and for convenience- Denial of exemption is not valid .[ S. 45, Transfer of Property Act, 1882, S.45 ]

S. 271(1)(c) : Penalty-Concealment-Revision order is quashed by the Tribunal-Consequential penalty order had no leg to stand.[S.115JB, 143(3), 263]

S. 271(1)(c) : Penalty-Concealment-Self assessment tax paid prior to issue of reopening of notice-Penalty is deleted. [S. 139, 140A, 148]

S. 268A : Appeal-Instructions-Circulars-Monetary limits-Audit objection-Appeal to Tribunal-Revenue filed appeal before Tribunal claiming that in view of circulars of CBDT case would fall under exception provided in Circular No. 3/2018 as same was case of audit objections-In view of latest CBDT Circular No. 5/2024, dated 15-3-2024, there was no exception to monetary limit regarding any audit objection-Due to low tax effect appeals of revenue would not be maintainable and were to be dismissed. [S.80P, 253]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash credits-Bank deposits-Capital gain-Purchase of agricultural after due date of filing of return-land se Reassessment proceedings initiated-No addition was made-Order is not erroneous and prejudicial to interest of revenue on issue of capital gain. [S. 45,54B, 68, 139(1), 147, 148]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Co-Operative society-Interest income-Income from other sources-Interest income derived from fixed deposits with cooperative banks-Entitle to deductions.[S.56, 80P(2)(d)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Salary-Perquisite-Difference in salary as per Form No.16 and salary disclosed in ITR-Amount received on VRS-The Assessing Officer had not conducted proper inquiries in respect of claims made by assesseee-Revision is held to be justified. [S.10(10C),10(10CC), 10(10B), 16, 17(2), 40(a)(v), Form No.16]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record-Subsequent judgement of Supreme Court-Order of Tribunal cannot be recalled based on subsequent judgment of Supreme Court when order of Tribunal had attained finality between parties-Deduction of payment towards employees’ contribution to PF and ESIC is that same should be deposited on or before due date prescribed under PF and ESIC Acts-Rectification application of Revenue is dismissed. [S. 36(1)(va), 139(1)), Code of Civil Procedure, 1908, Order XLVII, rule 1]