S. 254(1): Appellate Tribunal-Powers-Cross objection-Performance guarantee-Deposit-Jurisdictional issue-Ground raised orally-Validity of reassessment-Respondent can raise the issue orally-CIT(A) deleted the addition on merits-Revenue appeal-The Respondent can raise the grounds of validity of reassessment-Rule 27 of the ITAT Rules, 1963, does not propose raising the objection in writing-The respondent is well within his right to raise the ground orally-Reassessment is quashed on change of opinion. [S. 37, 69, 147, 148, ITAT R.1963, 27]

S. 250 : Appeal-Commissioner (Appeals)-Dismissal of appeal-Ex parte order-CIT(A) is directed to decide the appeal on merits. [S.246A]

S. 206C : Collection at source-Trading-Forest produce-Minor forest product-Forest product-Vegetable and animal origin, such as grasses, bamboos, canes, tans, dyes, oils, gums, resins, fibres, flosses, leaves, drugs, spices, poisons, edible products and animal prod-Minor forest products-Not liable to collect tax at source Agricultural product in the nature of Mahua Oil, Puhad, Ambadi, Dolma Kanji, Ratanjot and the cattle feed (Bhusa and Khal), etc. is not liable to collect tax at source. [S. 206C(1), 206C(6A), 206C(7) ]

S. 194LBC : Deduction at source-Investment in securitization trust-Assessee in default-Excess Interest Spread by securitization trust group-Pass through certificates by originator-No liability to deduct TDS from the payment of Excess Interest Spread by securitization trust-Not an assessee in default. [S.115TCA, Explanation (d), 201(1)]

S. 194C : Deduction at source-Contractors-Freight charges to transporters on behalf of third party under tripartite agreement-Provision is not attracted. [S. 201(1), 201(IA) ]

S. 153C : Assessment-Income of any other person-Search-Not mention of Document Identification No (DIN) in the assessment order-Subsequent separate communication of DIN is a superfluous exercise-Order invalid hence quashed-Circular No. 19 of 2019, dt. 14th Aug., 2019. [S.119, 292B ]

S. 153C : Assessment-Income of any other person-Search-Cash found in the premises-Cash kept for safe custody-No evidence produced to substantiate the claim-Addition is affirmed.

S. 153A: Assessment-Search-No incriminating documents-Loose sheet-Not estimate actual expenditure-Addition is not valid-Protective addition-Addition is confirmed in the assessment of director-No protective addition can be made in the assessment of the Company.

S. 153A: Assessment-Search-Admitted as undisclosed income-Not retracted-Order of CIT(A) deleting the addition is set aside. [S. 68]

S. 151 : Reassessment-Sanction for issue of notice-No approval is obtained before issue of reassessment notice-Re assessment is quashed as void ab-initio. [S. 147, 148]