S. 237: Refunds-Direction to Revenue to refund excess tax paid by assessee-Such direction was duly complied with after adjusting self-assessed liability-SLP to be disposed of. [Art. 136]

S. 197 : Deduction at source-Certificate for lower rate-Most Favoured Nation-DTAA-India-Netherlands [S. 9(1) (1), Art. 10]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Revenue itself wanted the Order under S. 148A(d) to be set aside with liberty to issue fresh notice under S. 148A(b)-Order of High Court rejecting Writ Application of the Petitioner thereby affirming the order under S. 148A(d) is set aside with liberty as prayed for. [S. 147, 148, 148A(b), 148A(d), Art. 136]

S. 80DD: Medical treatment of dependent-Disability-Amendment made to S. 80DD vide Finance Act, 2022 cannot be applied retrospectively to policies taken prior to 2014. [Art. 32]

S. 68 : Cash credits-SLP dismissed against High Court’s finding that additions were unjustified-Huge amounts deposited in foreign bank account in Geneva-Assessee pleaded that bank account belonged to nephew situated in UK-Assessee was an agriculturist and his name was struck from the bank account much prior to his visit to Geneva-SLP dismissed also on the ground of delay of 233 days, which was not explained properly.[Art. 136]

S. 68: Cash credits-AO made additions towards consideration received by assessee on sale of shares-Assessee had duly disclosed receipt of capital gains and offered for tax-No occasion for making addition-SLP to be dismissed on ground of low tax effect. [S. 153A, Art. 136].

S. 28(i): Business income-Capital gains-Delay of 752 days-Not satisfactorily explained-SLP of Revenue is dismissed.[S. 45, Art. 136]

S. 2(47) : Transfer-definition-“Extinguishment of any right there in”-Reduction of share capital by company amounts to reduction of rights of shareholder to share in distribution of net assets upon liquidation extinguished proportionately-Such reduction of rights is Transfer within the meaning of section 2(47) of the Act.[S. 45]

S. 50 :Capital gains – Depreciable assets – Block of assets – Rate of tax – Deeming fiction is to be confined only to section 50 and it could not convert short term capital asset into long term capital asset and vice versa for other purpose of Act – Rate of tax would be in terms of section 112 at rate of 20 percent and not 30 percent .[ S. 2(29AA) 2(29B ), 2( 42A) , 45 , 48,49, 112(1) ]

S. 276CC : Offences and prosecutions-Failure to furnish return of income-Subsequent filing of return-Adjudication in assessment proceedings is not relevant for prosecution-Petition to quash the proceeding is dismissed. [S. 139, 153A, 276C, Criminal Procedure code, 1973, S. 468]