S. 234E : Fee-Default in furnishing the statements-Tax deducted tax at source and deposited same on 18-5-2015 i.e. prior to amendment to section 200A(1) on 1-6-2015-Statement of TDS was filed on 23-6-2016-late fees could not be as default was prior to amendment. [S. 195, 200A (1)]

S. 201 : Deduction at source-Failure to deduct or pay-Bank-Interest paid to customer-Shown in their respective return-Should not be treated as an assessee-in-default-Matter remanded. [S. 194A, 197A, 201(1), 201(1A) Form No. 15G, 15H]

S. 195 : Deduction at source-Non-resident-Reimbursement of demurrage charges paid by assessee to a non-resident shipping company-Provision is not applicable. [S. 172]

S. 154 : Rectification of mistake-Tax on income referred in section 68, or section 69 or section 69B or section 69C or section 69D-Search-Surrender of income-Maximum rate of 60 % tax rate cannot be levied-Rectification order was quashed [S. 115BBE 132]

S. 153A : Assessment-Search-Return filed after date of search-Assessing officer has the jurisdiction to make the assessment whether any incriminating materials were found/seized in the course of search-Failure to explain source of cash deposit in his account and account of minor son-Addition is held to be justified. [S. 68, 132]

S. 144C : Reference to dispute resolution panel-Form no 35A could not be signed by Director-Scanned copy signed by director residing other country-Rejection of Form No 35A was quashed-Directed the DRP to decide the issue on merits. [S. 143(3)]

S. 144C : Reference to dispute resolution panel-Draft Assessment Order-Cannot be assumed to be final assessment. [S. 143(3)]

S. 144C : Reference to dispute resolution panel-Form no 35A not verified properly-Directed DRP to accept the original form and decide on merit. [Form No. 35A No Rule 34(5)]

S. 92C : Transfer pricing-Arm’s length price-Comparable-Computer software developer-RPT of comparable company-Knowledge Process Outsourcing (KPO)-Engineering and consulting services-Manufacturing of software-Functional similarity-working capital adjustment-Matter remanded.

S. 92C : Transfer pricing-Arm’s length price-Fully Compulsorily Convertible Debentures (FCCDs)-Interest adjustment-Interest should be market determined interest rate applicable to currency in which loan has to be repaid i.e. SBI Prime Lending Rate and not LIBOR based interest rate.