S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record –Bogus purchases–Estimation of profit at 1.5 % of on sales and purchases- Re hearing of appeal is not permissible in law-Writ against the rectification is held to be not bonafide – Cost of Rs 10000 is imposed on each of the petitioners. [S.69C, 254(1), Art. 226]

S. 147 : Reassessment–Change of opinion-Re assessment on the basis of subsequent assessment year where in deduction u/s. 80IA was not allowed-No tangible material having live link with the formation of belief-Reassessment notice is quashed. [S. 148, Art.226]

S. 147 : Reassessment-After the expiry of four years-Change of opinion-Sale of goods-Stock in trade–Reassessment notice is held to be bad in law. [S. 148, Art.226]

S. 144C : Reference to dispute resolution panel-Time limit– Tribunal remanding matter back to DRP-Time limit is to be computed after TPO passes the order and not from the date of DRP order. [S. 144C(5), 144C(13)]

S. 143(3) : Assessment–Remand by the Tribunal-Additional claim could be made in remand proceedings–Order of tribunal is set aside. [S. 144, 254(1)]

S. 139 : Return of income-Permanent Account Number (PAN)– Dispute between members of the society-Income tax Act does not allow both groups to file income tax returns having same PAN-AO is directed to pass a reasoned order with in period of eight weeks. [Art. 226]

S. 132(4A) : Search and seizure–Presumption–Appellate Tribunal-Duties-loose papers found during search-Not absolute–Order of Tribunal is set aside.[S. 158BC, 254(1)]

S. 40(a)(ia) : Amounts not deductible-Deduction at source– Professional fees–Payment made outside India–Not chargeable to tax in India – Not liable to deduct tax at source-DTAA-India-China. [S. 9(1)(vii), 90(2), 195]

S. 40(a)(i) : Amounts not deductible-Deduction at source– Commission or brokerage–Manufacture of goods as per specification–No principal-Agent relation ship–Not liable to deduct tax at source-No disallowances can be made. [S. 194H].

S. 40(a)(i) : Amounts not deductible-Interest-Party residing outside India–Exemption from Ministry of Finance–Not liable to deduct tax at source. [S. 10(15)(f), 195]