S. 263 : Commissioner-Revision of orders prejudicial to revenue-Search and seizure-Cash credits-Entries of unsecured loans-Failure to make necessary enquiries in reassessment proceedings-Assessment order is invalid-Revision order is invalid.[S. 68, 147, 153C]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash deposits-Share capital-share premium-Reassessment-Limitation-Relevant date for purpose of determination of period of limitation-Date of original assessment order and not date of reassessment order-Revision order is quashed.[S. 68, 147 148]

S. 254(2A): Appellate Tribunal-Stay-Pendency of rectification application before DRP-Tribunal has power to extend stay even beyond period of 365 days if proceedings are delayed for reasons not attributable to assesse.[S. 144C, 254(1)

S. 254(1) : Appellate Tribunal-Powers-Additional evidence-Share premium-The matter is remanded back to Assessing Officer for consideration after admitting additional evidence.[S. 56(2)(viib)]

S. 199 : Deduction at source-Credit for tax deducted-Credit of TDS in a financial year would be granted only when income corresponding to such TDS is assessed to tax in said financial year-Matter remanded.[Accounting Standard 9 (AS.9)]

S. 167B : Charge of tax-Shares of members unknown-Maximum marginal rate-Association of persons-Joint venture between TPL and Chint-Share in AOP’s profit is determinate i.e., TPL 99.99 per cent and Chint 0.01 per cent-TPL is domestic company and Chint was a Chinese company, 99.99 per cent of income of TPL is to be taxed at maximum marginal rate (MMR) of 30 per cent plus surcharge and cess and 0.01 per cent of income of Chint at MMR of 40 per cent plus surcharge and cess. [S. 2(31)(v)]

S. 156A : Modification and revision of notice in certain cases-Demand-Moratorium-CIRP proceeding was initiated against assessee and a resolution order was also passed-Assessing Officer was directed to modify demand payable in conformity with order of an Adjudicating Authority as defined in section 5(1) of the IBC and shall thereafter serve on assessee a notice of demand specifying sum payable, if any, and such notice of demand shall be deemed to be a notice under section 156 and provisions of Act shall apply accordingly. [S. 156, Insolvency and Bankruptcy Code, 2016, S. 5(1)]

S. 153C : Assessment-Income of any other person-Search-Time limit for initiation of proceedings-Legal grounds-Notice was issued on 11-1-2016-Six years for which proceeding under section 153C could have been initiated were assessment years 2015-16 to 2010-11-Assessing Officer had no jurisdiction to initiate proceeding under section 153C for assessment year 2008-09-Lack of jurisdiction-Assessment order is quashed.[S.132, 254(1), ITAT, Rule 27]

S. 149 : Reassessment-Time limit for notice-Notice issued on 29-7-2022 for assessment year 2015-16-Last date for issuing notice under old provision was 31-3-2022,-Notice is barred by limitation.[S. 147, 148]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Unexplained Moneys-Non-Resident-Erroneous facts-Reassessment order is quashed.[S.69A, 148, 148A(b)]