“Section 246(2)”

For a valid reassessment, the sanctioning authority must apply its mind to the reasons for reopening the assessment under Section 147. A mechanical endorsement like 'I am satisfied' without considering the material amounts to non-application of mind and invalidates the sanction under Section 151.

Granting registration under Section 12A or Section 12AA for charitable trusts requires the Commissioner to genuinely examine the trust's objects and past activities; once such registration is granted, the Assessing Officer cannot subsequently deny tax benefits by re-examining the trust's objects.

A penalty order under section 271(1)(c) is unsustainable if the Assessing Officer (AO) initiates proceedings for "concealment of particulars of income" but ultimately finds the assessee guilty of "furnishing inaccurate particulars of income", or vice versa. The AO cannot be uncertain in the penalty order as to which charge applies, as this error goes to the root of the matter and is not saved by section 292B.

A question of an Assessing Authority's jurisdiction cannot be disputed after assessment proceedings are completed. Such disputes can only be decided by the Commissioner or the Board, not by an appellate authority under Section 246.

Decisions relied upon by the Assessing Officer for concluding that an assessee does not exist for charitable purposes were not correct if the issue in those cases concerned cancellation of registration under Section 12A.

An appeal against an order charging interest under section 220(2) is maintainable. The CIT(Appeals) should consider such appeals on merits, particularly when supported by CBDT circulars.

Foreign commission paid to non-residents is not taxable in India, thus no TDS liability arises on such payments.

Section 292BB of the Income Tax Act is a rule of evidence concerning the service of notice, not the mandatory issuance of a notice under Section 143(2), which confers jurisdiction on the Assessing Officer.