S. 194J : Deduction at source – Fees for professional or technical services – Since no income was reflected in balance sheet and Profit & Loss account of HSL towards payment made by assessee and it was reimbursement of expenses incurred on cost to cost basis by assessee, it could not be treated as in default .if there is no income embedded in a payment TDS provision would not apply as the TDS is only an alternative method of collection of taxes [S. 201, 201(IA) ]
S. 194H : Deduction at source – Commission or brokerage –Reimbursement of expenses -Not liable to deduct tax at source .
S. 194C : Deduction at source – Contractors -Event managers – Tax to be deducted as a Contract or as technical services is substantial question of law admitted by High Court [ S.194J , 260A ]
S. 194C : Deduction at source – Contractors – Payment made to production house for programme software purchase , equipment hire etc . whether contract or technical services –Substantial question of law admitted by High Court [ S.194J, 260A ]
S. 194C : Deduction at source – Contractors – Placement fees/carriage fees to cable operators and MSO/DTH operators, which were payment for work contract and fees for technical services [ S.194J ]
S.192: Deduction at source – Salary – Commission paid to non-executives/independent directors could not be treated as salary and, not liable to deduct tax at source .[ S.15 ]
S. 147 : Reassessment – Cash credits-Accommodation entries -Bogus companies – information from investigation wing -No nexus with reasons recorded for initiating reassessment proceedings – Reassessment was held to be bad in law . [ S.68 , 143(1) ,148 ]
S.147: Reassessment – Cash credits –Information from investigation Wing – Loan from company working as an entry operator and earning bogus funds to provide advances to various persons- Reassessment was held to be valid [ S.143(1) ]
S.145 : Method of accounting -License fee -Merely on the basis of billing income cannot be assessed unless the income accrues to the assessee -Rule of constancy is followed .[S.5 ]
S.142(2A): Inquiry before assessment– Special audit–Court cannot go into sufficiency of reasons assigned by assessing authority for directing Special Audit