S. 197: Deduction at source-Certificate for lower rate-Payment to Non-resident-Withholding Certificate-Rejection of a Nil Withholding Certificate is unsustainable where the AO fails to consider the statutory factors under section 197 before determining the withholding tax liability-Matter remanded-DTAA-India-UK.[S. 195, Rule 28AA, Art. 13, Art. 226]

S. 153C: Assessment-Income of any other person-Search-Time limit-Interim relief leaving only eleven days of limitation-Limitation extendable only by sixty days under the proviso to the Explanation to section 153-Twelve-month period under section 153(6)(i) inapplicable to search assessments-Assessment beyond extended limitation quashed. [S. 132, 153, 153B, 153(6)(i)]

S. 153C: Assessment-Income of any other person-Satisfaction note based on incriminating material found during the course of search for other years-Notice issued for year under consideration under section 153C of the Act in the absence of any reason that incriminating material of other years will impact the taxability of assessment year is bad in law-SLP of revenue dismissed on account of delay of 448 days and 474 days. [Art. 136]

S. 153C: Assessment-Income of any other person-Search-No incriminating material was found-SLP of revenue dismissed.[Art. 136]

S. 153C: Assessment-Income of any other person-Search-Incriminating material belonging to or relating to a person other than the searched person is found during search proceedings-AO is required to proceed under section 153C and not under section 148-SLP of the revenue dismissed on account of delay of 56 days and also on merits. [S. 148, Art, 136]

S. 151 : Sanction for issue of notice-Reassessment proceedings are initiated beyond three years from the end of the relevant assessment year; prior sanction must be obtained from the specified authority under section 151(ii); sanction by any other authority is without jurisdiction and renders the reassessment proceedings invalid; SLP of the Revenue dismissed. [S. 147, 148, 148A(b), 151(ii), Art. 136]

S. 149: Reassessment-Time limit for notice-Period of limitation-Issuance of notice under section 148 within the limitation period is sufficient; inadvertent attachment errors or delayed viewing of the e-mail are curable defects and do not invalidate reassessment. [S. 147, 148, Art. 226]

S. 149: Reassessment-Time limit for notice-Notice under section 148 issued beyond the period of 6 years from the end of the relevant assessment year 2014-15 is barred by limitation-SLP of the revenue dismissed.[S. 148, Art. 136]

S. 149: Reassessment-Time limit for notice-Notice under section 148 issued beyond the period of limitation prescribed under the first proviso to section 149(1) of the Act is barred by limitation and liable to be quashed-SLP of revenue delayed by 320 days-SLP dismissed on account of delay. [S. 148, Art. 136]

S. 149: Reassessment-Time limit for notice-Notice dated 31.08.2024 issued under section 148 is beyond the period of six years from the end of Assessment Year 2016-17; therefore, the same is time-barred; SLP dismissed on account of delay of 309 days and also on merits. [S. 148, Art, 136]