S. 201 : Deduction at source-Failure to deduct or pay–Non-Resident–Royalty–Payment for purchase of copyrighted software –Not royalty–DTAA override the provisions of the Act-Lease Line Charges—Reimbursement of Expenses-Training availed of by employees of assessee Web based services available on internet— No technical knowledge imparted by service provider—No transfer of technology—Not fees for technical Services-Not liable to deduct tax at source-DTAA-India-USA. [S. 9(1)(vi), 9(1)(vii), 195, 201(1), 201(IA), Art. 12(b)]

S. 153C : Assessment-Income of any other person-Search– Audited balance sheet-Initiation of proceedings-Held to be not valid.

S. 153C : Assessment-Income of any other person–Search-Profit and loss account and balance sheet-Not Incriminating documents –Addition is held to be not valid. [S.132]

S. 153C : Assessment-Income of any other person–Search- Recording of satisfaction is mandatory even if the Assessing Officer of the person in respect of whom the search was conducted and the other person was one and the same-Additions were deleted. [S. 132]

S. 153A : Assessment–Search-Assessment completed on date of search–Additional ground raised before Tribunal -No incriminating material found-No jurisdiction to frame the assessment. [S. 69C, 254(1)]

S. 147 : Reassessment–With in four years-Non application of mind- Recording of incorrect figures-Merely repeating investigation report–Reassessment is held to be invalid. [S. 148]

S. 147 : Reassessment–With in four years-Provision for doubtful debt–Unabsorbed depreciation- Reassessment is held to be valid [S. 32(2), 148 ]

S. 147 : Reassessment–Capital asset -Agricultural land-Location of land from local limits of Chennai Municipal Corporation was relevant to decide as to whether said land was an agricultural land within meaning of S. 2(14)(iii) and distance of land from Chennai Metropolitan area was not relevant- Reassessment is held to be bad in law.[S. 2(14)(iii), 148]

S. 145 : Method of accounting–Valuation of closing stock at nil- Consistent method of accounting–Deletion of addition by CIT(A) is held to be justified.

S. 115JB : Book profit–Housing project-Development of housing project units which were neither units in SEZ nor developer of SEZ- Not entitle to exempt from MAT.[S. 80IB(10)]