S. 194J : Deduction at source-Fees for professional or technical services-Distribution of film-Minimum Guarantee Royalty (MGR)-Copy right-Royalty-Right of exhibition of cinematographic films-Not copy rights hence do not fall under term Royalty-Not liable to tax deduction at source-No disallowance can be made. [S. 40(a)(ia)]

S. 194H : Deduction at source-Commission or brokerage-Discount on pre-paid sim cards-Not required to deduct tax at source.

S. 154 : Rectification of mistake-Development of Special Economic Zone-Lease rent income offered under the head income from house property. [S. 22, 80IAB]

S. 154 : Rectification of mistake-Survey-Surrender of income-Undisclosed investment in stock-Provision of section 115BBE was not invoked in the original assessment proceedings-Charge of maximum rate in rectification proceedings is held to be not valid. [S. 69, 143(3) 115BBE]

S. 154 : Rectification of mistake-Unexplained purchases-Disallowance of 20%-Disallowance of entire purchase by passing a rectification order is held to be not valid. [S. 69C, 143(3)]

S. 153A : Assessment-Search-Share capital-Items already disclosed in original return and balance sheet-In absence of recovery of any incriminating material for making said addition in hands of assessee, said addition was to be deleted. [S. 68]

S. 153A : Assessment-Search-Several incriminating materials were found during course of search-Assessing Officer can interfere with original assessment while making assessment. [S. 143(1)(a)]

S. 147 : Reassessment-Sales promotion expenses-No new information-Reassessment is held to be bad in law. [S. 37(1), 148]

S. 147 : Reassessment-Under invoicing-Cash credits-Report of commission- Reassessment proceedings initiated merely on basis of report of a Commission appointed by Central Government that there was under invoicing of exports-Held to be bad in law-Pronouncement of order-Period during which lockdown was in force in country due to COVID 19 pandemic was to be excluded. [S. 68, 148, 255, ITAT R. 35]

S. 147 : Reassessment-Internal audit objection-Reimbursement of expenses-Failure to deduct tax at source-Reassessment is held to be not valid-90 days time period permitted under Rule 34(5) for pronouncing order was to be computed by deducting Covid-19 pandemic lockdown period. [S. 40(a)(ia), 148, 195, 255, ITATR. 34(5)]