CBDT Office Memorandums Not a Fetter on Commissioner’s Quasi-Judicial Authority

Punathil Nishriya Vs ITO (Kerala High Court) Introduction: A recent judgment by the Kerala High Court in the case of Punathil Nishriya vs. ITO raises important considerations regarding the authority of the Commissioner in quasi-judicial matters and the impact of CBDT Office Memorandums. The court’s decision allows for the deposition of orders with amounts less than 20% during pending appeals. Detailed Analysis: The petitioner in this case sought to challenge an order dated 20.07.2023 (Ext.P4) and requested the court to direct the 1st respondent (Income Tax Officer) to reconsider their st...