S. 194I : Deduction at source-Rent-Agreement with State Government for Development-External development charges-Not in the nature of rent-Tax not deductible at source on such charges. [S. 201(1), 201(IA), Art. 226]

S. 179 : Private company-Liability of directors-Only if Officer unable to recover tax due from Private company-Failure to record satisfaction-Show-cause notices and order quashed.[Art. 226]

S. 154 : Rectification of mistake-Mistake apparent from the record-Non-Resident-Service rendered on Foreign ship outside India-Failure to apply circular issued by Central Board of Direct taxes is a mistake apparent from the record-Entitle to exemption. [S.10(6)(viii), 143(1)]

S. 153C : Assessment-Income of any other person-Search-Writ petition against notice-Alternative remedy-Disputed questions of fact-Writ petition is dismissed. [S. 132, 246A, Art. 226]

S. 153C : Assessment-Income of any other person-Search-Limitation-Request for information from competent Authority-Further period of one year or till such time receipt of information by Assessing Officer-Completion of assessment within time-Block period-Block comprises assessment years immediately preceding assessment year relevant to previous year in which search conducted-Inclusion of Assessment years found to be in Order-Satisfaction note by Assessing Officer of searched person-Compliance with requirements of recording of satisfaction is mandatory-Warrant-Validity of search-Liberty to approach first Appellate authority. [S. 132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Search-No incriminating material was found-Limitation-Order of Tribunal allowing the appeal is affirmed. [S. 153A]

S. 153A : Assessment-Search-Limitation-Computation Of Limitation Period-Extension Of Time Limits By 2020 Act-Interim protections granted in writ petitions for certain assessment years Assessment orders for assessment years 2011-12, 2012-13 and 2019-20 are barred by Limitation-Orders set aside. [S. 132, 143(3), 153A, 153B, 271(1)(c), 271B, Taxation And Other Laws (Relaxation And Amendment Of Certain Provisions) Act, 2020, S. 3]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Effect of decision of Supreme Court In UOI v. Ashish Agarwal (2022) 444 ITR 1(SC)-Liberty available to matters at notice stage-Assessing Officer issuing second notice but allowing proceedings to lapse-Department cannot proceed for third time invoking liberty granted by Supreme Court-Notices and proceedings quashed. [S.. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Assessee to be given minimum seven days to reply excluding date of issue of notice and last date for submission of reply-Only six clear days given to assessee to file reply to notice-Matter remanded to provide assessee minimum seven clear days and maximum thirty days to file E-replies. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Disclosed all material facts during original assessment-Notice on ground methodology followed at time of scrutiny assessment ought to have been different-Not sustainable.[S.. 43B, 147, 148, 148A(b), 148A(d), Art. 226]