S. 192 : Deduction at source – Salary -Hospital- Consultant Doctors are not employees – Not liable to deduct tax at source as salary -Payments for call centre expenses — Tax deductible at source under S. 194C -Services of Managers of another organisation utilised — Reimbursement of expenses- Not liable to deduct tax at source [ S.194C, 194J , 201(1),201(IA) ]

S. 153C : Assessment – Income of any other person – Search – A satisfaction note is sine qua non and must be prepared by the Assessing Officer before he transmits the records to the Assessing Officer who has jurisdiction over such other person- Not furnishing the reasons for satisfaction – Proceedings is held to be in valid .

S.92C : Transfer pricing – Arm’s length price – Comparable – No question of law – Appeal is not maintainable .[ S.260A ]

S.69C: Unexplained expenditure – Bogus purchases – Sundry creditors – Only profit element embedded in credits can be taxed- Restricted to 25% of element of profit . [ S.37 , 69A ]

S. 43B : Deductions on actual payment -Interest payable to Banks — Conversion of unpaid interest into funded interest Loan- Not allowable as deduction- Explanation 3C to section 43B inserted with retrospective effect from 1-4-1989 by the Finance Act , 2006 .

S. 40A(3) :Expenses or payments not deductible – Cash payments exceeding prescribed limits – Purchases were supported by dealers invoice along with valid transit receipt , receipt documents etc – Disallowance is held to be not justified .[ R.6DD ]

S. 11 : Property held for charitable purposes – Application of income- Excess of expenditure of earlier years adjusted against income of relevant accounting year, amounts to application of income — adjustment will have to be excluded from the income of the trust under section 11(1)(a) .[ S.11(1)(a),12 ]

S. 260A : Appeal – High Court – Strictures -The Court deprecated the tendency of the Revenue to file appeals even though the issues were ex facie covered by the decisions of the jurisdictional High Courts or even the Supreme Court of India – Copy of order is forwarded to Chief Commissioner , CBDT , Mimistry of Finance , Department of revenue for need ful action – Interest income- Held to be not assessable .[ S.4 ]

S. 271(1)(c) : Penalty–Concealment–Quantum addition was not challenged – Receipts were not offered to tax in the return-Levy of penalty is held to be not justified.

S. 271(1)(c) : Penalty–Concealment–Difference in TDS- Agreed addition- levy of penalty is held to be not valid.