S. 197 : Deduction at source-Certificate for lower rate-Certificate of nil deduction-Non-Resident-Payments received from ONGC for work done inside and outside India-Powers of Assessing Officer while considering application for certificate-Difference of opinion between members of division bench-Matter to be referred to appropriate Bench-DTAA-India-The United Arab Emirates. [R. 28, 28AA, Art. 7]

S. 154 : Rectification of mistake-Book profits-Amounts disallowed under Section 14A cannot be added back to book profits-Debatable issue rectification order is not valid. [S. 14A, 115JB]

S. 153A : Assessment-Search or requisition-Undisclosed income-Amounts credited to employees account-Admission by employees that the amount belong to the assessee-Peak and gross profit theory-Not accepted-Addition is held to be justified. [S. 132, 133A]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Request for adjournment to file response not granted-Assessing authority obliged to decide dispute in respect of a mount involved in transaction with reference to material submitted by assessee. [S. 148, 149, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Violation of principle of natural justice-Not furnished full information-Matter remanded. [S. 147, 148, Art. 226]

S. 148 : Reassessment-Notice-Limitation-Doctrine of substantial compliance-Mere signing of notice is not sufficient-Date of issue would be date on which notice was served on assessee-Notice dated 31-3-2018 served on assessee through E-Mail on 18-4-2018 for AY. 2011-12-Notice barred by limitation. [S. 147, 149, 282, R. 127, Art. 226]

S. 148 : Reassessment-Notice-Proceedings under Insolvency And Bankruptcy Code, 2016-Not a bar for issue of notice of Reassessment. [S. 147, Insolvency and Bankruptcy Code, 2016, S. 10, 30(6), 31, Art. 226]

S. 148 : Reassessment-Notice-No procedural irregularity-Notice issued and objections raised-Notice valid-Writ is not maintainable there is no violation of law or principle of natural justice. [S. 147, Art. 226]

S. 147 : Reassessment-Order passed after considering the objections-Assessment order was passed-Writ is not maintainable. [S. 148, Art. 226]

S. 147 : Reassessment-No tangible material-Notice not valid. [S. 148, Art. 226]