S. 147 : Reassessment –With in four years-Change of opinion – Payment to related parties – Incentives to senior employees – Difference in VAT return and Turnover as per profit and loss account -Reconciliation – Questions asked in the course of original assessment proceedings – No discussion in the assessment order – Reassessment notice was quashed. [ S. 40A(2)(b) , 148 , Art , 226 ]

S. 88 : Tax arrear-Amount payable-Adjustment of refund was made as per request of the assessee-Not disclosed the truth and suppressed the communication-Writ petition was dismissed. [S. 245, Art. 226]

S. 184 : Charge of tax and surcharge-Payment of tax-Credit for advance tax-Credit for advance tax must be given-Directed the respondents to issue certificate as required by Rule 4(5). [S. 183, 185 IT ACT, S. 139, 199, 210, 219, Art. 226]

S. 9(c) : Act not to apply in certain cases-Disqualification of persons under prosecution-Named in charge sheet and first information report-Denial of benefit is held too be valid. [Indian Penal Code, 1860, S 120B, 420, Prevention of Corruption Act, 1988, S. 131(1)(d), 132(2), Art. 226]

S. 4 : Filing of declaration and particulars to be furnished-Pendency of appeal-Condonation of delay-Appeal admitted prior to January 2020-Appeal pending-Directed the respondent to process the declaration. [S. 2(1)(a), Art. 226]

S. 2(f) : Disputed tax-Amount payable by declarant-Interest-Interest granted under section 244A cannot be recovered by revenue authority under Direct Tax Vivad se Vishwas Act, 2020, by adding same to amount of disputed tax payable by assessee. [S. 3, IT ACT, S. 234D, 244A, Art. 226]

S. 2(1)(a)(ii) : Appellant-Locus standi-Rejection of application on the ground that there is no clarity of Legal Heirs-Appeal was filed beyond limitation period-Rejection of application was held to be not valid-Directed the Designated Authority to accept the declaration [S. 3, 4(1), IT Act, S. 132, Art. 226]

S. 264 : Commissioner-Revision of other orders-Interest receipt was shown as capital receipt-Commissioner refusing to follow the order of Tribunal and dismissing the revision application-Order of Tribunal is binding on the Commissioner-Order of Commissioner was quashed-If any judgements to be relied the Commissioner should give an opportunity to the petitioner to deal with those judgements-Matter remanded. [S. 4, Art.226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Exempt income-Strategic investment-View taken by Assessing Officer being a possible view could not have been interfered by Commissioner-Order of Tribunal quashing the revision was affirmed. [S. 14A, R. 8D, 260A]