S. 201: Deduction at source-Failure to deduct or pay-Assessee in default-Non-deduction of TDS on property purchases-Benefit of First Proviso-Burden of proof on assessee-Non-filing of Form 26A or supporting CA certificate-Interest under Section 201(1A) applicable until seller’s tax filing-Penalty imposed for non-deduction of TDS [S. 194IA,201(1),201(IA), 271C, Form No 26A]

S. 195: Deduction at source-Non-resident-Other sums-TDS on sales commission and sales promotion expenses paid to non-residents-No TDS deductible if non-resident payee does not have a permanent establishment or business connection in India-No tax liability under the Act or DTAA-Disallowance of expenses deleted [S. 5(2)(b), 9(1)(i), 40(a)(ia) 194H]

S. 154 : Rectification of mistake-Mistake apparent from the record-Source of investment-Accepted in original assessment proceedings-Change of opinion is not possible.

S. 153D: Assessment-Search-Approval granted by Joint Commissioner of Income-tax in the case of 49 assessees on the same date on which draft assessment order was passed by the AO-Non application of mind-Assessment order is invalid-CBDT Circular no. 3 of 2008 dated 12.3.2008.[S. 132, 153A]

S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Date of satisfaction note is to be reckoned as date of handing over of materials for purpose of assumption of jurisdiction-Time limit of calculating six years was to be calculated from this date-Assessment year 2008-09 is time barred-No incriminating documents-Addition is deleted. [S. 68, 132]

S. 153C : Assessment-Income of any other person-Search-No incriminating material is found-Addition is not valid [S.132, 153A]

S. 153A: Assessment-Search-Unexplained expenditure-Payment of commission-Bogus sales-Gross profit offered to tax-Gross profit is available to set off-Unaccounted advances paid to employees-Only remaining amount is taxable-Stock-Valuation at average rate of method is acceptable-Addition is deleted-Undisclosed income is accepted-Further addition towards purchases is not justified. [S. 69, 69C, 132, 133]

S. 153A-Assessment-Search-Unabated assessment-No incriminating material-Addition is not valid.[S. 132]

S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Specified Authority-Sanction by Principal Commissioner of Income Tax-Reassessment notice and order is bad in law.[S.148, 148A(b), 148A(d), 151(ii)]

S. 148 : Reassessment-Notice-Additional ground-Legal issue-Time for issue notice under Section 143(2) against original return had not lapsed-Reassessment notice is bad in law-Limitation-Time-limit to be reckoned from date of return whether filed under Section 139(1) or 139(5) or in response to notice under section 142(1). [S. 139(1),139(2),139(5), 142(1), 143(2) 147]