S. 10A : Free trade zone–Export sale proceeds not received in India in foreign exchange within time specified-Assessee seeking extension of time-No extension of time allowed after period of six months from end of year and application not rejected—Amounts includible in export turnover though received belatedly-Disallowance of payments for failure to deduct tax at source enhancing taxable income of assessee—Entitled to exemption on enhanced income. [S. 40(a)(ia)]

S. 220 : Collection and recovery-Assessee deemed in default– Stay -The AO has directed the assessee to pay 20% of tax demanded.- Appellate authority started the hearing – Writ is not entertained. [Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default– Stay –Society–Cash credits- Denial of exemption–Direction to pay only one percent of tax demanded as against 50% of disputed tax in dispute.[S. 68, 80P]

S. 194C : Deduction at source–Contractors-Up-linking Service Agreement-Payments made to Multi System Operators on account of channel carriage fees and other payments related to Up-linking charges and down-linking charges, Bandwidth and Air Time charges–Not in the nature of fees for technical services–Levy of penalty is held to be not valid.[S. 9(1)(vii), 194J, 221(1), 271C]

S. 147 : Reassessment–With in four years-Survey–Expenditure Failure to produce documents in the original assessment proceedings-Reassessment notice is held to be valid. [S. 133A, 148, Art.226]

S. 147 : Reassessment-After the expiry of four years- In absence of any failure on part of assessee to disclose fully and truly all material facts at time of assessment- Reassessment proceedings is held to be bad in law. [S. 80IA, 148]

S. 147 : Reassessment–After the expiry of four years-Failure to deduct tax deducted at source- Management consultancy fees- No omission or failure on assessee’s part to disclose all material facts relevant to original assessment proceedings- Notice for reassessment is held to be not valid. [S. 40(a)(ia), 194J, 195]

S. 92C : Transfer pricing–Arm’s length price–Comparables- Functional similarity- Merely because the assessee included an entity in list of comparbles would not bar the assessee from contending other wise before TPO- Order of Tribunal is affirmed. [S. 92B]

S. 80IB(10) : Housing projects-Complied all the conditions- Failure to complete the project attributable to the assesee-Entitle to deduction.

S. 69 : Unexplained investments-Undisclosed income- Immoveable property-Purchase consideration is alleged to be undervalued-Deletion of addition is held to be justified. [S. 158BC]