S. 245R : Advance rulings – Capital gains- Application for advance ruling could not be rejected merely because it involved computation of capital gains as computation of capital gains is embedded in concept of valuation and question pertained to legal admissibility of transaction and not of any valuation -DTAA-India – Mauritius [ Art 13(4) ]

S. 234A : Interest – Default in furnishing return of income – Disclosure was made after the search action rejection of application for waiver of interest was held to be justified [ S.119, 132(4), 234B 234C ]

S. 220 : Collection and recovery – Assessee deemed in default – Pursuant to two orders passed by writ Courts, assessee had deposited 30 per cent of demand and had furnished bank guarantee to extent of 45 per cent of demand. Since interest of revenue stood adequately safeguarded, revenue was not justified in increasing tax demand to 55 per cent of dues .

S. 201 : Deduction at source – Failure to deduct or pay –Short deduction of tax at source -Finding that there was no default hence not liable to interest .[ S.201(IA) ]

S. 194LA : Deduction at source – Compensation on acquisition of certain immoveable property – Where Land Acquisition Collector while disbursing compensation, had deducted tax at source and deposited same with Income Tax Department, better course of action, which was in consonance with provisions of Act, for assessee should have been to approach concerned Assessing Officer and raise issue that no tax was payable on compensation/enhanced compensation received by them as their land was agricultural land – Collector was directed to follow the procedure prescribed by Kerala High Court . [ S.197 ]

S. 194J : Deduction at source – Fees for professional or technical services – Since no income was reflected in balance sheet and Profit & Loss account of HSL towards payment made by assessee and it was reimbursement of expenses incurred on cost to cost basis by assessee, it could not be treated as in default .if there is no income embedded in a payment TDS provision would not apply as the TDS is only an alternative method of collection of taxes [S. 201, 201(IA) ]

S. 194H : Deduction at source – Commission or brokerage –Reimbursement of expenses -Not liable to deduct tax at source .

S. 194C : Deduction at source – Contractors -Event managers – Tax to be deducted as a Contract or as technical services is substantial question of law admitted by High Court [ S.194J , 260A ]

S. 194C : Deduction at source – Contractors – Payment made to production house for programme software purchase , equipment hire etc . whether contract or technical services –Substantial question of law admitted by High Court [ S.194J, 260A ]

S. 194C : Deduction at source – Contractors – Placement fees/carriage fees to cable operators and MSO/DTH operators, which were payment for work contract and fees for technical services [ S.194J ]