S. 222 Collection and recovery – Certificate to Tax Recovery Officer -Time limit for sale of attached immovable property – the order of the DRT becomes final only after expiry of period prescribed for filing appeal and therefore 3 year period as stipulated by rule 68B for sale of attached property should be determined from such date when the order of DRT becomes final- Sale was held to be not time barred .

S. 206C: Collection at source – Scrap – Items used by the buyers in manufacturing of other items cannot be considered as scrap,hence not liable to collect tax at source .

S. 195A; Deduction at source – Net of tax – Salary and tax both were borne KSEB, in whose project assessees were employed and, therefore, provisions is applicable -Amount paid as tax would be included as salary [ S.192 ]

S. 179: Private Company – Liability of Directors – Assessing Officer can exercise jurisdiction to recover the dues of the company against the director only when it fails to recover its dues from Private limited company.Order of AO was set aside

S. 147: Reassessment – Capital gains – Opening WDV of land was shown by assessee at lesser amount in its statement of fixed accounts but, while filling return of income, assessee had shown cost of land at much higher amount, reassessment was held to be justified.[ S.45 , 148 ]

S. 147:Reassessment- Two notices- Reassessment was initiated vide two notices and the second notice was beyond prescribed period. No where it was stated that second notice was in continuation of first one hence reassessment was invalid.[ S.143(1),148 ]

S. 147: Reassessment –Change of opinion-Since there was no material on record to indicate that there was a failure on part of the assessee to disclose fully and truly relevant material during original assessment proceedings, initiation of reassessment proceedings was without jurisdiction. [ S.80IA(4), 148 ]

S. 145: Method of accounting – Mere non-maintainence of stock register could not form the basis of rejection of books of accounts

S. 112 : Tax on long term capital gains -Foreign company on long-term capital gains arising on sale of equity shares of an Indian company being listed in securities, will be 10 per cent (plus surcharge and cess) of amount of capital gains as per proviso to S. 112(1)-DTAA- India -Japan [ S.45, Art. 4,13 ]

S. 80IB: Industrial undertakings – Interest Subsidy – Revenue subsidies received by the assessee towards reimbursement of cost could be said to have direct nexus with profits and gains of industrial undertaking and eligible for deduction.