S. 147 : Reassessment – Change of opinion- Initiation of reassessment proceedings merely on the basis of change of opinion is invalid [S. 10(23G), 40(a),148, 260A]

S. 69 : Unexplained investments – Onus is on the assessee to explain the cash deposits and if no explanation is given, the amount can be assessed as assessee’s income. [S. 68, 260A ]

S. 68 : Cash credits – Firm – Capital account- Onus was on assessee firm to prove the capacity of the partners who introduced cash as capital in the assessee firm – Amendment brought by Finance Act, 2021 which requires establishment of ‘source of source’ is clarificatory in nature. [S. 260A]

S. 12AA : Cancellation of registration-Trust or institution-Survey-No incriminating material was found-Accommodation entries- Cancellation of registration without giving an opportunity of cross examination is not valid. [S. 12A, 133A]

S.147: Reassessment – After the expiry of four years – Valuation of equity shares – Share premium – Income from other sources – No failure to disclose material facts – Notice of reassessment and order disposing objection was quashed .[ S. 56(2) (viib), 148 , Art , 226 ]

S.147: Reassessment – After the expiry of four years – Loans and advances to sister concern – Allegation of colourable device – No failure to disclose material facts – Notice of reassessment and order disposing objection was quashed . [S. 69, 148 , Art , 226 ]

S. 292CC : Authorisation and assessment in case of search or requisition-Separately in the name of each person-Validity-Search was conducted after introduction of section 292CC and not by applying provision retrospectively-Amendment is clarificatory in nature-Challenge to constitutional validity of section 292CC was rejected. [S. 132,132A, Art. 226]

S. 264 : Commissioner-Revision of other orders-Withdrawal of application-Rejection of prayer for withdrawal of application-decided the application on merit-Directed the Commissioner to decide the application for withdrawal as expeditiously as possible. [Art. 226]

S. 254(1) : Appellate Tribunal-Duties-Remand by High Court-Industrial undertakings-Infrastructure development-Industrial Park-Tribunal is required to record finding of its own and could not merely remand matter to Assessing Officer. [S. 80IA(4)(iii]

S. 226 : Collection and recovery-Modes of recovery-Stay-Deduction at source-Interest-Bank deposits-Failure to deduct or pay-Application for stay of demand was dismissed-Directed to deposit 20 per cent of total demand-DTAA-India-China. [S. 201 (1), Art. 11(3), Art. 226]