S.147: Reassessment – After the expiry of four years – Life Insurance company – Actuarial report- No failure to disclose material facts – Reassessment is not justified [ S.44, 57 , 148, Art , 226 ]

S. 40(a)(ia): Amounts not deductible – Deduction at source – Commission paid to Chairman and manging director – Part of salary provision of section 192 is applicable and not section 194H- TDS is deductible at the time of payment and not when the provision was made – No disallowance can be made . [ S. 192 , 194H , Form No 16 ]

S. 36(1)(vii) :Bad debt -Deposit made with sister concern –Capital ,loss – Interest income assessed as business income – Waiver of principal amount and interest accrued – Allowable as bad debt . [ S. 28(i), 36(2)(i)]

S. 12AA : Procedure for registration –Trust or institution- Object to develop training and research centre to facilitate skill development to entire chain of work force engaged at various levels in garment and textile industry- Entitle for registration -Delay condoned [ S. 2(15), 11, 253 , Companies Act , 2013 , S. 8 ]

S. 148: Reassessment – Notice – Section 148 notices issued by the Assessing Officers shall be deemed to have been issued under Section 148A as substituted by the Finance Act, 2021 and to be treated as show¬ cause notices in terms of Section 148A(b) of the Act -The Assessing Officers shall, within 30 days from 04-05-2022, provide the information and material relied upon so that the assessees can reply to the notices within two weeks thereafter. Decision to apply to all such notices quashed by High Courts throughout Country [ S. 148A(b), 149,Art , 142 ]

S. 276C : Offences and prosecutions-Evasion of tax-Alteration of charges based on additional witness-Sanction already obtained-New or fresh sanction is not required-Disputed question of fact of non-issuance of notice by Tax Recovery Officer can be confronted in Trial framing additional charge based on additional evidence-Order passed by Special Sessions Judge, in allowing application was affirmed.[S. 276(1),276C(2), 279(1) ; Code of Criminal Procedure, 1973,S.216(5)]

S. 264 : Commissioner-Revision of other orders-Rejection of revision application merely on the ground that failure to submit reply is quashed and set aside-Matter remanded. [Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Power to grant stay-Buy back of shares-Stay of further proceedings when appeal against the revision order is pending before the Appellate Tribunal-Revision order was stayed for twelve weeks. [S. 253(7), 254(1), Art. 226, Companies Act, 1956, S.77A]

S. 254(2A) : Appellate Tribunal-Stay-Delay in disposal of appeal is not attributable to assessee-Tribunal can grant extension of stay of demand beyond 365 days in deserving cases. [Art. 226]

S. 254(2A) : Appellate Tribunal-Stay-Delay in disposal of appeal is not attributable to assessee-Tribunal can grant extension of stay of demand beyond 365 days in deserving cases. [Art. 226]