S. 195A : Deduction at source-Net of tax-Technical services-Income deemed to accrue or arise in India-Royalty-UK based university-Agreed to bear Indian taxes-Required to gross-up amount of fees for technical services (FTS) paid to university, for purpose of deducting TDS under India-UK DTAA-SLP dismissed as withdrawn-DTAA-India-UK [S.9(1)(vi), 9(1(vii), art. 12]

S. 194I : Deduction at source-Rent-Agreement with State Government for Development-External development charges-Not in the nature of rent-Tax not deductible at source on such charges.-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 201(1), 201(IA), Art. 136]

S. 194H : Deduction at source-Commission or brokerage-Distributors-Payment from distributor had no link with further sale made by distributor, said payment could not be treated as commission or brokerage as described in Explanation to section 194H-SLP of Revenue is dismissed.[Art. 136]

S. 158BD : Block assessment-Undisclosed income of any other person-Satisfaction note is sine qua non and must be prepared by Assessing Officer who has jurisdiction over such other person-Assessment order is illegal-Additions confirmed by the Tribunal is deleted. [S. 131, 153C, 260A]

S. 153B : Assessment-Search and seizure-Time limit-Revision-Conclusion of search-Locker-Last panchanamas-No seizure-Strict interpretation of statutes-Strict rule of interpretation-Not barred by limitation-Reserving the assessee to raise contentions regarding jurisdiction error vis-a-vis limitation period before appropriate authority despite order passed against assessee. [S. 132, 263, Art. 136]

S. 153 : Assessment-Limitation-Tribunal order-and partially remanded-Limitation would commence from the date the date when the Assessing Officer becomes aware of the order of the Tribunal-Order is barred by limitation-Order of Tribunal is affirmed. [S. 153(2A), 254]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Service of notice-Not issued on the registered email of the compamy-The notice and consequential order passed under section 148A(d) sent to secondary e-mail address were quashed and set aside. [S. 56(2)(x), 148, 148A(b). 148A(d), 282, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Income below taxable income-In active email-Principe of natural justice-Notice and order is quashed-The matter is remitted back to the Assessing Officer for reconsideration afresh in accordance with law. [S. 143(3), 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Typographical error-Sanction for issue of notice-Principal commissioner-Non application of mind-[S. 148 148A(b), 148A(d), 151, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-More than three years from end of relevant assessment year after obtaining approval from Chief Commissioner-Chief Commissioner was not a specified authority under clause (ii) of section 151-Reassessment notice and order disposing the objection is quashed. [S. 148, 148A(b), 148A(d), 151(ii), 195, Art. 226]