S. 263 : Commissioner-Revision of orders prejudicial to revenue– Loan from group companies-Assessing Officer had taken a conscious decision regarding non-applicability of section 2(22)(e) to loan amount in question while passing the original assessment order – Revision is held to be not valid. [S. 2(22)(e), 143(3), 153A]

S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record–Tribunal can recall order and change its mind in even if draft copy is signed and order is dictated in open Court- Rectification application is held to be not maintainable. [S. 254(1) R.46A]

S. 254(1) : Appellate Tribunal-Powers-Stay-Valuation of unquoted equity shares–Huge difference-Prima facie-Based on method laid down in Rule 11UA-Stay is granted.[S. 56, R.11UA]

S. 234E : Fee-Default in furnishing the statements- Return of tax deducted at source—Late Fee—Fee can be levied only in respect of return filed after 1-6-2015.- Irrespective of the period to which the quarterly return pertains, where the return is filed after June 1, 2015, the AO can levy fee under S 234E-At the same time, for the period of delay falling prior to June 1, 2015, there could not be any levy of fees as the assumption of jurisdiction to levy such fees was prospective in nature. [S. 200A]

S. 234B : Interest-Advance tax–Notified person–Assets attached- Assessing Officer is directed to recompute interest liability after reducing amount of tax deductible at source on source on income earned. [S. 234C]

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)]