S.246A : Appeal – Commissioner (Appeals) – Appealable orders – Denial of liability to pay interest under section 139(8) and 215 of the Act can be challenged in appeal – waiver or reduction of such interests are not appealable orders [ S.246(c)]

S. 245N : Advance rulings – AAR Rulings can be challenged but not directly in the Supreme Court. [S. 245S, Constitution of India-Arts. 136, 226, 227]

S. 245C : Settlement Commission – Application for settlement of cases – Undisclosed income – full and true disclosure – Revising the application during the course of proceedings is not permissible. [S. 245D(4)]

S. 195 : Deduction of tax at source – Payment to non-resident – Obligation to deduct tax arises only when a remittance is chargeable to tax under the Act – No obligation to deduct tax arises the moment a remittance is made [S. 192, 195(1) , 195(2), 237 ]

S. 194E : Deduction of tax at source – Non-resident – Payments to sports associations being in the nature of guarantee money were intricately connected with the event – Income accrues and arises in India and assessee was liable to deduct tax at source under section 194E – The obligation to deduct tax is not affected by the DTAA. [ S. 9(1) ,115BBA ]

S. 168: Executors – Taxability of estate in the hands of executor –Representative assessee- Existence of Trust – Prior to trust – taxable as executor – not as trustee. [ 160 ]

S. 154 :Rectification of mistake – Mistake apparent on the record must be an obvious and patent mistake – It should not require a long drawn process of reasoning where there may be conceivably two opinions – ITO was incompetent to pass orders under section 154 of the Act to rectify the assessment. [ Indian Income-tax Act, 1922 ,S.17(1) ]

S. 153C: Assessment – Income of any other person – Search and seizure – Complying with the requirement of recording of satisfaction is mandatory – If AO of the searched person and the other person is same, a single satisfaction note prepared by the AO stating that documents seized belonged to the other person and not the searched person would tantamount to complying with the mandatory requirements of section 153C. [S.132(1), 133A , 158BD]

S. 147: Reassessment-Change of opinion-Deduction was allowed in the original assessment- on the same facts to hold that the excess deduction was allowed will be change of opinion-therefore, reassessment was held to be bad in law. [S. 10A,148]

S. 145: Method of accounting – Valuation of inventories – Finished goods – Goods valued below cost – Stock in trade- Rejection of method of valuation is held to be justified .