Section-specific penalty + s. 270A/271C/271CA framework.
16. Prosecution exposure
Section 276 series — wilful evasion.
17. Cross-statute interplay
PMLA / FEMA / DTAA / Companies Act / GST.
18. Repeal & saving — 1961 → 2025
Section 536 saves pending proceedings.
HISTORICAL CONTEXT
Section 133A authorises the income-tax authority to conduct surveys at business / profession premises during business hours. Unlike section 132 (search and seizure), section 133A is a lighter inspection tool — permitting inventory-taking, document examination, and statement recording, but NOT permitting seizure (except impounding of books).
The CIT v. S. Khader Khan Son (SC) decision established that statements recorded under section 133A do not carry the same evidentiary value as statements under section 132(4) — the latter being on oath under search powers. Section 133A statements can be retracted with credible reasons, and their evidentiary value depends on corroboration with material evidence.
Section 133A(2A), inserted by FA 2002, created a specialised TDS / TCS survey power — enabling verification of withholding compliance at deductor / collector premises. The FA 2003 expansion of impound power (s. 133A(3)(ia)) gave surveys teeth — but courts have constrained the 'for such period as thinks fit' formulation through reasonableness review.
The transition to the Income-tax Act, 2025 preserves the substantive framework; pending proceedings continue under section 536 saving.
FINANCE ACT AMENDMENT TIMELINE
■ FA 1964 — Section 133A inserted (originally a limited inspection power).
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
▸ Calcutta Discount Co. Ltd. v. Income-tax Officer, Companies District I, Calcutta (1961) 41 ITR 191 ; AIR 1961 SC 372 (Supreme Court — Constitution Bench)
Facts. The assessee challenged a section 34 reassessment notice on the ground that the ITO had no jurisdictional foundation to reopen; the Revenue contended that the writ jurisdiction was ousted by the statutory appeals scheme.
Issue. Whether the High Court's jurisdiction under Article 226 is ousted by the existence of a statutory remedy where the reassessment notice itself lacks jurisdictional foundation.
HELD. Existence of an alternative statutory remedy does not oust Article 226 jurisdiction where the impugned action is wholly without jurisdiction. The burden is on the assessee to disclose all primary facts; the duty to draw inferences rests with the assessing officer.
“The duty of the assessee in every case is to disclose fully and truly all primary facts. Once all primary facts are before the assessing authority, he requires no further assistance by way of disclosure.”
Relevance. Foundational on the boundary between assessee's disclosure duty and the ITO's investigative duty — supports challenges to s. 147/148 (1961) / s. 281 (2025) reassessments on jurisdictional grounds.
Facts. The assessee received a section 148 notice but was not furnished the reasons recorded by the ITO. The High Court declined to interfere and directed the assessee to pursue the assessment.
Issue. Procedure for challenge to a section 148 reassessment notice — must the assessee be furnished reasons recorded, and may objections be raised before participating in the assessment.
HELD. On receipt of notice under section 148, the assessee may file a return and seek reasons recorded by the ITO. The ITO is bound to furnish the reasons within a reasonable time; the assessee may then file objections, which the ITO must dispose of by a speaking order before proceeding with the assessment.
“We clarify that when a notice under section 148 is issued, the proper course of action for the noticee is to file return and if he so desires, to seek reasons for issuing the notices. The Assessing Officer is bound to furnish reasons within a reasonable time.”
Relevance. Operative authority on the reassessment procedure under sections 147/148 — still good law for the procedural framework even after the FA 2021 overhaul and Ashish Agarwal.
▸ Commissioner of Income-tax v. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 ; (2010) 11 SCC 762 (Supreme Court)
Facts. The assessee claimed deduction of interest on borrowings used for investment in shares yielding tax-free dividend. The deduction was disallowed under section 14A. The Department levied penalty under section 271(1)(c) for concealment / inaccurate particulars.
Issue. Whether a mere disallowance of a deduction — without any falsehood in the particulars furnished — attracts penalty under section 271(1)(c).
HELD. Penalty under section 271(1)(c) is not attracted merely because a claim for deduction is disallowed. The assessee's claim must be shown to be false, frivolous, or made without bona fides; mere unsustainability does not amount to concealment or furnishing of inaccurate particulars.
“A mere making of the claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding the income of the assessee. Such claim made in the Return cannot amount to inaccurate particulars.”
Relevance. Cornerstone authority for resisting penalty under section 271(1)(c) / section 270A — applies to disallowed deductions, transfer-pricing adjustments, head-of-income re-characterisations where a bona-fide claim was made.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
▸ CBDT Circular No. 6 of 2019 dated 20 March 2019
Subject. Withdrawal of low-tax-effect appeals — monetary thresholds
Substance. Revised monetary thresholds for departmental appeals — ITAT (Rs 50L), HC (Rs 1 Cr), SC (Rs 2 Cr); subsequently further revised. Operates as a non-statutory limitation on the Revenue's appellate engagement, binding under section 119.
Substance. Procedural guidance for AOs handling transitional reassessment notices for AYs 2013-14 to 2017-18 affected by Ashish Agarwal and Rajeev Bansal. Sets out the form of section 148A inquiry, time-bar calculation under TOLA, and JAO/FAO jurisdiction in faceless cases.
WORKED EXAMPLES
Illustration — Illustration 1
Facts. Survey at Co A's office premises during business hours.
Computation.
Section 133A(1) — entry permitted during business hours.
Inventory of stock / cash; statement on oath limited (Khader Khan Son SC).
No seizure power (vs s.
132).
Result. Survey limited — no seizure, statement evidentiary value limited.
Illustration — Illustration 2
Facts. Survey statement records undisclosed income Rs 50 L.
Computation.
CIT v.
S.
Khader Khan Son (SC) — survey statement has limited evidentiary value (vs s.
132(4) which is full evidentiary value).
Retraction credible if prompt.
Result. Survey statement less binding than s. 132(4).
Illustration — Illustration 3
Facts. During survey, AO impounds books of account.
Computation.
Section 133A(3)(ia) — impound permitted with reasons recorded.
'For such period as thinks fit' — but limited by reasonableness.
Reasons must be in writing.
Result. Impound permitted with reasoned order.
Illustration — Illustration 4
Facts. TDS-survey under s. 133A(2A) at withholding-agent premises.
Computation.
Section 133A(2A) — limited to TDS / TCS verification.
AO checks deduction status, deposit records, Form 24Q / 26Q compliance.
STATUTORY ARCHITECTURE — 18-ROW MAP
01. Section & marginal note
Section 133A — Survey.
02. Sub-section structure
Per operative text.
03. Operative trigger
Per section's substantive trigger.
04. Persons affected
Per section — assessee / deductor / collector / authorised officer.
05. Time anchor
Per section's timing rule.
06. Income anchor
Per section's quantum framework.
07. Residential-status nexus
Resident / NR application per section.
08. Rate / charge mechanism
Per section's rate framework.
09. TDS / TCS interaction
Withholding / collection mechanism if applicable.
10. Advance-tax obligation
Interaction with advance-tax framework.
11. Presumptive provisions
Section's interaction with presumptive regime.
12. Exemption / deduction
Available carve-outs / exemptions.
13. Refund / credit
Refund mechanism / credit framework.
14. Return / disclosure
Reporting requirements.
15. Penalty exposure
Section-specific penalty + s. 270A/271C/271CA framework.
16. Prosecution exposure
Section 276 series — wilful evasion.
17. Cross-statute interplay
PMLA / FEMA / DTAA / Companies Act / GST.
18. Repeal & saving — 1961 → 2025
Section 536 saves pending proceedings.
HISTORICAL CONTEXT
Section 133A authorises the income-tax authority to conduct surveys at business / profession premises during business hours. Unlike section 132 (search and seizure), section 133A is a lighter inspection tool — permitting inventory-taking, document examination, and statement recording, but NOT permitting seizure (except impounding of books).
The CIT v. S. Khader Khan Son (SC) decision established that statements recorded under section 133A do not carry the same evidentiary value as statements under section 132(4) — the latter being on oath under search powers. Section 133A statements can be retracted with credible reasons, and their evidentiary value depends on corroboration with material evidence.
Section 133A(2A), inserted by FA 2002, created a specialised TDS / TCS survey power — enabling verification of withholding compliance at deductor / collector premises. The FA 2003 expansion of impound power (s. 133A(3)(ia)) gave surveys teeth — but courts have constrained the 'for such period as thinks fit' formulation through reasonableness review.
The transition to the Income-tax Act, 2025 preserves the substantive framework; pending proceedings continue under section 536 saving.
FINANCE ACT AMENDMENT TIMELINE
■ FA 1964 — Section 133A inserted (originally a limited inspection power).
■ FA 2002 — Section 133A(2A) — TDS / TCS specialised survey.
■ FA 2003 — Impound power (s. 133A(3)(ia)) inserted.
■ Khader Khan Son (SC, 2008) — survey-statement evidentiary value.
■ FA 2017 — Procedural updates.
■ FA 2021 — Section 133A(6) — coordination with faceless framework.
■ FA 2024 — Conforming amendments.
■ ITA 2025 — Survey framework preserved.
JUDICIAL EVOLUTION — VERIFIED LANDMARK AUTHORITIES
▸ Commissioner of Income-tax v. Vatika Township Pvt. Ltd. (2014) 367 ITR 466 ; (2015) 1 SCC 1 (Supreme Court — 5-Judge Constitution Bench)
Facts. The Department sought to apply a surcharge provision retrospectively to block-period assessments. The assessee contended that the amendment was substantive and could not have retrospective operation absent express legislative direction.
Issue. Whether amendments to taxing statutes operate prospectively unless the legislature has expressly or by necessary implication conferred retrospective effect.
HELD. The Constitution Bench reaffirmed the general rule against retrospectivity of taxing statutes. A taxing provision must be construed prospectively unless the language compels otherwise; mere insertion or substitution by amendment is not sufficient to deny vested rights.
“Of the various rules guiding how a legislation has to be interpreted, one established rule is that unless a contrary intention appears, a legislation is presumed not to be intended to have a retrospective operation.”
Relevance. Anchor authority for any argument that an amendment to a charging or computational provision must apply only from the AY notified — useful in transitional disputes around FA 2025 and the 1961 → 2025 changeover.
▸ Mathuram Agrawal v. State of Madhya Pradesh (1999) 8 SCC 667 ; (2000) 1 SCR 1 (Supreme Court)
Facts. A municipal levy was challenged on the ground that the charging provision did not clearly specify the rate, the persons charged, and the measure of tax.
Issue. Whether a tax can be imposed in the absence of a clear, unambiguous charging provision identifying the subject, measure, rate, and incidence.
HELD. Article 265 demands that tax be levied only by clear authority of law. The four components — taxable event, person, rate, and measure — must be clearly discernible from the charging provision; ambiguity is fatal to the levy.
“The intention of the Legislature in a taxation statute is to be gathered from the language of the provisions, particularly when the language is plain and unambiguous. In a taxing Act it is not possible to assume any intention or governing purpose other than what is given expression to.”
Relevance. Foundational authority on the rigour required of charging sections — underpins arguments that ambiguous deeming fictions, surcharge formulas, and rate prescriptions must be strictly construed.
▸ Calcutta Discount Co. Ltd. v. Income-tax Officer, Companies District I, Calcutta (1961) 41 ITR 191 ; AIR 1961 SC 372 (Supreme Court — Constitution Bench)
Facts. The assessee challenged a section 34 reassessment notice on the ground that the ITO had no jurisdictional foundation to reopen; the Revenue contended that the writ jurisdiction was ousted by the statutory appeals scheme.
Issue. Whether the High Court's jurisdiction under Article 226 is ousted by the existence of a statutory remedy where the reassessment notice itself lacks jurisdictional foundation.
HELD. Existence of an alternative statutory remedy does not oust Article 226 jurisdiction where the impugned action is wholly without jurisdiction. The burden is on the assessee to disclose all primary facts; the duty to draw inferences rests with the assessing officer.
“The duty of the assessee in every case is to disclose fully and truly all primary facts. Once all primary facts are before the assessing authority, he requires no further assistance by way of disclosure.”
Relevance. Foundational on the boundary between assessee's disclosure duty and the ITO's investigative duty — supports challenges to s. 147/148 (1961) / s. 281 (2025) reassessments on jurisdictional grounds.
▸ GKN Driveshafts (India) Ltd. v. Income-tax Officer (2003) 259 ITR 19 ; (2003) 1 SCC 72 (Supreme Court)
Facts. The assessee received a section 148 notice but was not furnished the reasons recorded by the ITO. The High Court declined to interfere and directed the assessee to pursue the assessment.
Issue. Procedure for challenge to a section 148 reassessment notice — must the assessee be furnished reasons recorded, and may objections be raised before participating in the assessment.
HELD. On receipt of notice under section 148, the assessee may file a return and seek reasons recorded by the ITO. The ITO is bound to furnish the reasons within a reasonable time; the assessee may then file objections, which the ITO must dispose of by a speaking order before proceeding with the assessment.
“We clarify that when a notice under section 148 is issued, the proper course of action for the noticee is to file return and if he so desires, to seek reasons for issuing the notices. The Assessing Officer is bound to furnish reasons within a reasonable time.”
Relevance. Operative authority on the reassessment procedure under sections 147/148 — still good law for the procedural framework even after the FA 2021 overhaul and Ashish Agarwal.
▸ Commissioner of Income-tax v. Reliance Petroproducts (P) Ltd. (2010) 322 ITR 158 ; (2010) 11 SCC 762 (Supreme Court)
Facts. The assessee claimed deduction of interest on borrowings used for investment in shares yielding tax-free dividend. The deduction was disallowed under section 14A. The Department levied penalty under section 271(1)(c) for concealment / inaccurate particulars.
Issue. Whether a mere disallowance of a deduction — without any falsehood in the particulars furnished — attracts penalty under section 271(1)(c).
HELD. Penalty under section 271(1)(c) is not attracted merely because a claim for deduction is disallowed. The assessee's claim must be shown to be false, frivolous, or made without bona fides; mere unsustainability does not amount to concealment or furnishing of inaccurate particulars.
“A mere making of the claim, which is not sustainable in law, by itself, will not amount to furnishing inaccurate particulars regarding the income of the assessee. Such claim made in the Return cannot amount to inaccurate particulars.”
Relevance. Cornerstone authority for resisting penalty under section 271(1)(c) / section 270A — applies to disallowed deductions, transfer-pricing adjustments, head-of-income re-characterisations where a bona-fide claim was made.
CBDT CIRCULARS — ECOSYSTEM
▸ CBDT Circular No. 14(XL-35) of 1955 dated 11 April 1955
Subject. Duty of officers to assist assessees in claiming and securing relief
Substance. Foundational circular directing that the AO should not exploit assessee ignorance to deny legitimate reliefs; officer is required to draw attention to refunds or reliefs to which the assessee is entitled. The circular has been judicially noted in several appellate decisions and remains operative for first-appellate practice.
▸ CBDT Circular No. 549 dated 31 October 1989
Subject. Explanatory notes — Finance Act 1989 amendments (incl. PY unification)
Substance. Explained the FA 1987 / FA 1989 amendments unifying the previous year with the financial year preceding the AY, including transitional provisions for assessees with different accounting years. Useful in any controversy on the timing of accrual / chargeability for early post-1989 AYs.
▸ CBDT Circular No. 5 of 2014 dated 11 February 2014
Subject. Section 14A — dis-allowance even where no exempt income earned (since modulated)
Substance. Initially directed AOs to apply Rule 8D disallowance under section 14A even where no exempt income was earned in the year; subsequently modulated by Cheminvest (Del HC) and Maxopp (SC). FA 2022 amendment to section 14A re-asserted the position but remains under litigation.
▸ CBDT Circular No. 6 of 2019 dated 20 March 2019
Subject. Withdrawal of low-tax-effect appeals — monetary thresholds
Substance. Revised monetary thresholds for departmental appeals — ITAT (Rs 50L), HC (Rs 1 Cr), SC (Rs 2 Cr); subsequently further revised. Operates as a non-statutory limitation on the Revenue's appellate engagement, binding under section 119.
▸ CBDT Circular No. 5 of 2024 dated 15 March 2024
Subject. Procedure for transitional reassessment notices post-Ashish Agarwal / Rajeev Bansal
Substance. Procedural guidance for AOs handling transitional reassessment notices for AYs 2013-14 to 2017-18 affected by Ashish Agarwal and Rajeev Bansal. Sets out the form of section 148A inquiry, time-bar calculation under TOLA, and JAO/FAO jurisdiction in faceless cases.
WORKED EXAMPLES
Illustration — Illustration 1
Facts. Survey at Co A's office premises during business hours.
Computation.
Section 133A(1) — entry permitted during business hours.
Inventory of stock / cash; statement on oath limited (Khader Khan Son SC).
No seizure power (vs s.
132).
Result. Survey limited — no seizure, statement evidentiary value limited.
Illustration — Illustration 2
Facts. Survey statement records undisclosed income Rs 50 L.
Computation.
CIT v.
S.
Khader Khan Son (SC) — survey statement has limited evidentiary value (vs s.
132(4) which is full evidentiary value).
Retraction credible if prompt.
Result. Survey statement less binding than s. 132(4).
Illustration — Illustration 3
Facts. During survey, AO impounds books of account.
Computation.
Section 133A(3)(ia) — impound permitted with reasons recorded.
'For such period as thinks fit' — but limited by reasonableness.
Reasons must be in writing.
Result. Impound permitted with reasoned order.
Illustration — Illustration 4
Facts. TDS-survey under s. 133A(2A) at withholding-agent premises.
Computation.
Section 133A(2A) — limited to TDS / TCS verification.
AO checks deduction status, deposit records, Form 24Q / 26Q compliance.
Result. TDS-specific survey — limited scope.
Illustration — Illustration 5
Facts. Survey converted to search mid-way.
Computation.
Section 133A → 132 conversion requires fresh warrant.
Procedural defect if not authorised.
Article 226 writ for jurisdictional defect.
Result. Section 133A → 132 conversion needs warrant.
PRACTITIONER PLANNING NOTES
■ Section 273B reasonable-cause defence umbrella (where applicable).
■ Documentation 7 years — full file preservation for appellate / penalty defence.
■ Limitation discipline — diarise all statutory clocks.
■ Form-filing discipline — within due dates u/s 139(1) / section-specific.
■ Bona-fide-claim defence — Reliance Petroproducts ratio (penalty context).
■ Vatika Township anchor — prospective amendment for FA changes.
■ Mathuram Agrawal anchor — strict construction.
■ K.P. Varghese — object-and-purpose interpretation.
■ Calcutta Discount Article 226 — writ where remedy not efficacious.
■ Hindustan Coca-Cola — no double counting / recovery (TDS context).
■ GE India — s. 195 chargeability test (NR withholding).
■ Engineering Analysis — narrow royalty / FTS (treaty interpretation).
■ Azadi Bachao — treaty-shopping permissible.
■ Section 234A / B / C — interest framework.
■ Section 144B faceless overlay where applicable.
LITIGATION DEFENCE
■ Vatika Township — prospective amendment.
■ Mathuram Agrawal — strict construction of charging / penal provisions.
■ K.P. Varghese — object-and-purpose.
■ Calcutta Discount — Article 226 writ.
■ GE India — s. 195 chargeability test (NR withholding).
■ Engineering Analysis — narrow royalty / FTS.
■ Azadi Bachao — treaty interpretation.
■ Hindustan Coca-Cola — no double recovery (TDS / TCS context).
■ Vodafone International — indirect transfer / NR framework.
■ Excel Industries — real-income / accrual.
■ Reliance Petroproducts — bona-fide claim defence (penalty context).
■ Dilip N. Shroff — penalty discretion.
■ Malabar Industrial — s. 263 revision twin-condition.
■ GKN Driveshafts — reassessment / writ procedural.
■ BC Srinivasa Setty — computation-machinery failure.
■ Section 273B reasonable-cause umbrella.
STEP-BY-STEP PROCEDURE — 15 STEPS
Step 1. Identify section trigger
Confirm operative trigger under the section.
Step 2. Quantum determination
Compute the threshold / quantum / rate.
Step 3. Timing compliance
Diarise statutory clock for action.
Step 4. Form / certificate preparation
Prepare required forms / certificates.
Step 5. Documentation
Compile supporting documents.
Step 6. Compliance filing
File required returns / forms within due dates.
Step 7. Payment / deposit
Discharge tax / TDS / TCS / penalty liabilities.
Step 8. Reconciliation
Reconcile with Form 26AS / AIS / TIS.
Step 9. Notice / SCN handling
Respond to notices within statutory clock.
Step 10. Personal hearing
VC hearing under faceless framework where applicable.
Step 11. Order / determination
Receive AO / authority order.
Step 12. Rectification s. 154
Apply for rectification of apparent mistakes.
Step 13. Appeal s. 246A
File appeal to CIT(A) within 30 days.
Step 14. Further appeals
ITAT / HC / SC as required.
Step 15. Refund + s. 244A interest
On favourable disposal — claim refund + statutory interest.
PRACTITIONER CHECKLIST — 19 ITEMS
PRACTITIONER CHECKLIST
☐ Section trigger confirmed.
☐ Quantum / rate computation verified.
☐ Statutory clock diarised.
☐ Forms / certificates prepared.
☐ Documentation 7 years preserved.
☐ Compliance filings within due dates.
☐ Payment / deposit discharge.
☐ Form 26AS / AIS reconciliation.
☐ Notice / SCN reply prepared.
☐ VC hearing minute (faceless).
☐ Reasoned order received.
☐ Section 154 rectification application (if applicable).
☐ Section 246A appeal Form 35 (if adverse).
☐ Section 220(6) stay application.
☐ Quantum-appeal status tracked.
☐ Section 273B defence framed (penalty context).
☐ Case-law compilation.
☐ Refund + s. 244A claim post favourable disposal.
☐ Full file index preserved.
CROSS-REFERENCES (28+)
CROSS-REFERENCES
▸ Section 132Search — stronger power.
▸ Section 132ARequisition.
▸ Section 142AEstimate of investments.
▸ Section 153ASearch assessment.
▸ Section 271 / 270APenalty framework.
▸ Khader Khan Son (SC)Survey-statement evidentiary value.
▸ Pullangode Rubber (SC)Admission ratio.
▸ Article 226 — ConstitutionWrit for jurisdictional defect.
▸ Article 21 — ConstitutionProcedural safeguards.
▸ Form 26ASTDS / TCS verification reference.
▸ CBDT Faceless Survey SchemeOperative framework.
▸ Section 246AFirst appellate route.
▸ Section 253ITAT appeal.
▸ Section 260A / 261HC / SC.
▸ Section 263 / 264Revision framework.
▸ Section 154Rectification.
▸ Section 156Demand notice.
▸ Section 220(6)Stay of demand.
▸ Section 244ARefund interest.
▸ Section 270A / 271 / 271AAB / 271AACPenalty framework.
▸ Section 273A / 273AA / 273BWaiver / immunity / reasonable cause.
▸ Section 144BFaceless overlay.
▸ Section 144CDRP route.
▸ Section 282Service of notice.
▸ Section 234A / 234B / 234CInterest framework.
▸ Section 139(1)Return-filing due date.
▸ Vatika Township (SC)Prospective amendment.
▸ Mathuram Agrawal (SC)Strict construction.
▸ K.P. Varghese (SC)Object-and-purpose.
▸ Calcutta Discount (SC)Article 226 writ.
▸ Section 536 — ITA 2025Saves pending proceedings.
▸ Article 14 / 226 / 265 — ConstitutionConstitutional safeguards.