S. 194A: Deduction of tax at source-Interest other than interest on securities-Assessee in default-Reimbursement of interest to Group Company-Not liable to deduct TDS by the Assessee-Levy of interest is deleted. [S. 201(1), 201(IA)]
S. 194A: Deduction of tax at source-Interest other than interest on securities-Assessee in default-Reimbursement of interest to Group Company-Not liable to deduct TDS by the Assessee-Levy of interest is deleted. [S. 201(1), 201(IA)]
S.156A: Modification and revision of notice in certain cases-Demand and recovery-Since the resolution plan has yet to be finalized, remanding the appeal to the AO is necessary-The AO will take the required steps before the NCLT in compliance with s.156A and the IBC provisions. [S. 156, 178, Insolvency and Bankruptcy Code, 2016S. 14]
S. 154 : Rectification of mistake-Mistake apparent from the record-Tax deducted at source-Rectification proposing withdrawal of refund of tax deducted at source-Rectification order is not valid.[S. 143(1)]
S. 153B : Assessment-Search-Time limit-Assessment of any other person-Satisfaction note was drawn in assessment year 2018-19-Order passed beyond period of limitation of six years-Barred by limitation [S. 143(3),153C]
S. 153B: Assessment-Search-Time limit-Limitation to pass the assessment order expired on 31.12.2020 [S. 69B, 132,153A, 153C]
S. 153C : Assessment-Income of any other person-Search-Satisfaction note prepared without application of mind and without referring to the incriminating material found during the course of Search-Assessment order is quashed..[S. 132]
S. 153A: Assessment-Search-Addition can not be be made in the absence of incriminating material found during the search. [S. 69A, 69C, 132]
S. 153A: Assessment-Search-No addition can be made merely on the basis of statement-On money-Presumption-Addition is deleted.[S. 132, 153C, 292C]
S. 153A: Assessment-Search-Revenue followed detailed guidelines during the search-Approval under the section cannot be considered as granted mechanically-Matter is restored to CIT(A). [S. 153D]
S. 151 : Reassessment-Sanction for issue of notice–Notice u/s 148 issued beyond 3-year period-As per amended Section 151 (post 01.04.2021), approval from PCCIT/CCIT was required, but approval was taken from PCIT-Reassessment proceedings quashed. [S. 147, 148]