S. 239 : Refunds – Limitation – Condonation of delay -Delay in pronouncement of judgement by AAR -Return claiming the return belatedly – Revenue authorities were to be directed to condone delay in filing return subject to payment of cost and, thereupon, assessee’s claim for refund would be decided in accordance with law .

S. 220 : Collection and recovery – Assessee deemed in default – Stay of demand – Pendency of appeal before CIT(A) – Demand of payment of tax is reduced from 20% to 10 % .

S. 194A : Deduction at source – Interest other than interest on securities – Branches of Bank -Deduction of tax at source- Jurisdiction of Assessing Officer- Branches of bank were spread over many districts, Assessing Officer (TDS) of district, where in Head Office was situated, had no jurisdiction in respect of branches spread over other districts. [ S.133A, 201, 260A ]

S. 179 : Private company – Liability of directors – There was nothing on record to suggest that tax dues could not be recovered from company and same could be attributed to any gross neglect, misfeasance or breach of duty on part of assessee in relation to affairs of company, impugned recovery proceedings deserved to be quashed .

S. 153C : Assessment – Income of any other person – Search- Cash receipts- No payments were made in relevant assessment year- , impugned addition made in assessment year- Deletion of addition is held to be justified . [ S.69A ]

S. 147 :Reassessment -Salaries paid to employees – Reconciliation statement was filed – Reassessment proceedings was quashed .[ S.37(1), 148 ]

S.147: Reassessment-After the expiry of four years- Capital gains- No failure on the part of assessee to disclose truly and fairly material facts – Reassessment is held to be bad in law . [ S.50C 54B , 148 ]

S. 115JB : Book profit – Provision for diminution in value of investment- Written off in the books – Addition cannot be made to book profit . [ S. 115JB(2)(i), Accounting Standard (AS) 13 ]

S. 92C:Transfer pricing – Arm’s length price – Commission – commission paid to Associated Enterprise at rate of 7.84 per cent as against 11 per cent paid to unrelated party was at ALP- Deletion of addition is held to be valid .

S.45: Capital gains- Revaluation of capital asset and crediting to partners current account and treating it as loan from partners – Amounted to violation of clauses (a) and (c) of proviso to S. 47(xiii)Transaction amounted to transfer of a capital asset – liability to pay tax on such capital gain would fall not on assessee-firm but on successor company. [ S. 47 (xiii) (a) , 47 (xiii) (b) , 47A ]