S. 195 : Deduction at source-Non-resident-Reinsurance premium amount transferred to NRRs-NRRs did not have PE in India-Not liable to deduct TDS-DTAA-India-Singapore. [S. 9(1)(i), 201, Art. 7]

S. 194LD : Interest on certain bonds and Government securities-Interest earned from said NCDs-Bonds-Debentures-In absence of specific definition of bonds in Act, term ‘bonds’ used in section 194LD should be considered as including NCDs and accordingly concessional rate of 5 per cent-DTAA-India-Germany. [S. 9(1)(v) 115A, Art. 11]

S. 154 : Rectification of mistake-Mistake apparent from the record-Income from house property-Discrepancy in receipts as shown in 26AS-Service tax-Reconciled by assessee with sufficient evidence adduced before revenue and this resulted in higher amount being shown in Form 26AS, additions made for difference was to be deleted. [S. 22, 143(1)]

S. 154 : Rectification of mistake-Mistake apparent from the record-Refunds-Interest-No adjudication by Chief Commissioner / Commissioner-Additional ground-Denial of interest by passing rectification order is held to be not valid. [S. 244A (2)]

S. 154 : Rectification of mistake-Mistake apparent from the record -Property held for charitable purposes-Failure to file Form No 10 along with return of income-Form was filed before the Assessing authority before completion of assessment-Eligible for exemption-Rejection of rectification application was not valid. [S. 11(2)(c), 143(1), 154, R. 17, Form No. 10]

S. 154 : Rectification of mistake-Mistake apparent from the record-Industrial undertakings-Failure to audit report-Audit report in Form 10CCB was up loaded on receipt of intimation u/s 143(1)-The Assessing Officer is directed to grant the relief. [S. 80IA, 143(1), Form-10BBC]

S. 148 : Reassessment-Notice-Time limit for issuance of notice under section 143(2) has not expired-Notice for reassessment can be issued, [S. 139, 143(2), 143(3), 147]

S. 145 : Method of accounting-Discrepancy in receipts as shown in 26AS-Estimation of income-Contractor-Without pointing out any defects in the books of account merely on the basis of discrepancy in in receipts as shown in 26AS and books of account addition cannot be made. [S. 68, 133(6), Form 26AS]

S. 145 : Method of accounting-Accrual of income-Unearned revenue-Additional evidence produced-Matter is remanded for reconsideration-Provision made reversed in next year-Remanded for verification. [S. 5, 40(a)(ia)]

S. 143(1)(a) : Assessment-Intimation-Insurance premium-Premature surrender of life insurance policy-Though TDS under section 194DA was contemplated on gross amount paid under a life insurance policy, but amount of income which could be added by means of adjustment under section 143(1)(a)(vi) would be such sum received as reduced by amount of premium paid. [S. 10(10D), 143(a)(vi), 194DA Form No. 26AS]