S. 263 : Commissioner-Revision of orders prejudicial to revenue-Amalgamation of Companies-Department Knowing About Dissolution of assessee-PCIT to take notice of amalgamation and substitute successor while passing revision Order after hearing to amalgamated company-Commissioner passing revision order against non-existent company-Order ab initio void.

S. 263 : Revision of orders prejudicial to revenue–Payments liable to deduction of tax at source-Assessee crediting interest to unsecured loan accounts of parties before close of year-Decision of high court that tax not required to be deducted in case where assessee paid interest during year-AO rightly not making disallowance-Order neither erroneous nor prejudicial to interests of revenue-Revision order passed by Commissioner invalid. [S. 40(a)(ia)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue– CIT to himself conduct enquiries-AO has carried out detailed inquiry and verification of the documents and is satisfied with the net profit shown by the eligible unit as well as the nature of expenses incurred by eligible and non eligible units, then without there being found any discrepancy or defect, such assessment order cannot be set aside. [S. 80IC]

S. 244A : Refund–Interest on refunds-Amount refundable to assessee on account of interest subsidy being capital in nature-CIT(A)’s denial for grant of such interest-without giving opportunity of hearing-Matter remanded.

S. 201 : Deduction at source-Failure to deduct or pay-Time limit for passing order–Amendment by Finance Act, 2014 is only procedural–Order has been passed within seven years-Order within limitation. [S. 2(22)(e), 194, 201(3)]

S. 199 : Deduction at source–Credit to tax deducted–Point in time –Credit in the year in which income is assessable-TDS credit is allowed. [R. 37BA]

S. 195 : Deduction at source-Non-resident-Other sums-Payment for purchase of software was in the nature of business income, in the absence of PE, tax was not required to be deducted on such payments. [S. 37, 92]

S. 194H : Deduction at source–Bank guarantee commission–No principal-agent relationship–Not liable deduct tax at source. [s. 2(28A) and 194A(3)(iii)]

S. 153A : Assessment-Search or requisition-Addition made towards undisclosed income on the basis of statement made after the period of search-having no nexus with the incriminating material found during search–not sustainable. [S. 132(4)]

S. 153A : Assessment–Search-Addition to income on account of receipt of share application money and premium-AO not referring to any seized material or other material found during course of search-Addition is unsustainable.