S. 194A : Deduction at source-Interest other than interest on securities-Excess interest retained by nonbanking financial companies-loans purchased by bank-Upfront payment and allowing the originating NBFCs to retain part interest on such loan paid by the borrowers-No obligation to deduct tax at source-NBFCs have already offered to tax in their returns of income the interest earned on loans sold to the assessee-Levy of tax under section 201 (1) and levy of interest u/s 201(IA ) for failure to deduct u/s 194A, 194H or 194J is not applicable. [S.2(28A 194A, 194H, 194J 201(1), 201(IA)]

S. 154 : Rectification of mistake-Mistake apparent from the record-Survey-Stock offered-Assessed as business income-Rectification order is quashed. [S.69D, 115BBE, 143(3)]

S. 154 : Rectification of mistake-Mistake apparent from the record-Limitation-Non-service of intimation under S. 143(1)-The four year limitation seeking rectification starts ticking the moment the assessee is in receipt of the order-Rejection of application being time barred is not justified.[S.80P(2), 143(1), 154(7)]

S. 153D : Assessment-Search-Approval–A common and consolidated approval has been granted-Approval is bad in law-Order is quashed. [S. 153A]

S. 153A: Assessment-Search-Unabated assessment-No incriminating material-Information from audited balance sheet-Addition is deleted. [S. 132]

S. 153A: Assessment-Search-Bank Locker in the name of assessee’s father-Search warrant in the name of assessee-Keys of the locker were found from the residential premises of the assessee-Issue of notice is valid-Long term capital gains on sale of equity shares-Addition is deleted.[S.68, 69C 132]

S. 153 : Assessment-Limitation-Date of order-Dispatch-Body of the assessment order, the date of passing of the order has been mentioned as 28th Dec., 2016-Assessment order was dispatched only on 2nd Jan., 2017 as per the postal track consignment-Assessment order is time barred.[S. 143(3)]

S. 147 : Reassessment-Repatriated the amounts invested in non-convertible debentures in the earlier years-No escapement of income-Reassessment notice and order is quashed.[S. 148]

S. 144C : Reference to dispute resolution panel-Order passed prior to issue of direction of DRP-Order passed after direction of DRP is not valid-Additional ground is admitted-Delay in filing of an appeal is condoned.[S.143(3), 144C(13), 253(5)]

S. 143(1) : Assessment-Intimation-Communication for adjustment was sent at the updated email address of the assessee is valid communication-Late payment of employees contribution-Disallowance is justified-Matter is remanded to the AO to find out any extension was granted under the relevant statutes for payment of employees’ contribution to ESI/ PF [36(1)(va ), 43B, 139(1), 282,R. 127(2)]