S. 148: Reassessment – Income of any other person – Search – Search material pertains to third party – Notice of reassessment under Section 148 is held without jurisdiction – Section 153C and not section 148 is to be resorted to- Notice of reassessment is quashed and set aside . [S. 132, 147, 151(1), 153A, 153C, Art. 226]

S. 264: Commissioner-Revision of other orders-Credit for tax deducted at source-Double taxation agreement-Refund interest-Respondents are directed to refund the amount along with statutory interest forthwith. [S. 90, 155(14), 199, Form No 266AS, Art. 226]

S. 254(1) : Appellate Tribunal-Powers-Additional evidence-No application was moved-Failure to produce will during assessment proceedings-Order of Tribunal is affirmed.[R.46A, 260A. Order 41, Rule, 27CPC]

S. 245D : Settlement Commission-Settlement of cases-Procedure-Application-Conditions-Full and true disclosure-Revision of application-No full and true disclosure-Order of Settlement Commission is set aside.[S.245C, 245D (4),245H, Art. 226]

S. 234A : Interest-Default in furnishing return of income-Marginal delay in filing of return-Interest u/s 234A is waived-Advance tax-Deferment of advance tax-Waiver or reduction-Board’s F. No. 400/129/2002-IT(B), dt. 26th June, 2006-CBDT Circular, does not specifically deal with waiver of interest under S.. 234B and 234C-Does not specifically deal with waiver of interest-No impediments operating against the assessee from paying the advance tax within the time line under S. 211. [S. 119, 211, 234B, 234C, Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Stay-Direction to pay 15 per cent of total demand.[S. 250, Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Stay-Direction to pay 15 per cent of total demand-Condition imposed on the assessee by the Single Judge to remit 15 per cent of the total demand while granting stay of recovery proceedings is set aside; rest of the directions in the impugned judgment are not interfered with.[S. 250, Art. 226]

S. 201 : Deduction at source-Failure to deduct or pay-Interest-Tax deduction at source-Failure to deduct tax at source-Capital gains tax-Limitation-Alternative remedy-Writ petition is dismissed-DTAA-India-UK-Strictures-Observations made by the Assessing Officer is directed to be expunged within two days and directed the ASG to take appropriate measures. [S. 45, 158(2),195, 201(1), 201(IA), Art. 14, Art. 226]

S. 197 : Deduction at source-Certificate for lower rate-Stock options-Salaries-Specified security-Property-Since the assessee did not make any payment towards the ESOPs and continues to retain all the ESOPs even after the receipt of compensation, the entire receipt qualifies as the perquisite and becomes liable to be taxed under the head “Salaries”-Assessee is not entitled to a ‘nil’ certificate of deduction [S.2(14), 15, 17(2), 192,, Sale of Goods Act, 1930, Companies Act, 2013, Art. 226 ]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice is issued by Jurisdictional Assessing Officer and not under faceless mechanism-Notice and order is quashed. [S. 148, 148A(b) 148A(d), 151A, Art. 226]