S. 195 : Deduction at source-Non-resident-Fees for technical services-Consulting services-Commission for procuring orders from customers -No permanent establishment or business connection in India-Not liable to deduct tax at source. [S. 9(1)(vii), 201(1), 201(IA)]

S. 154 : Rectification of mistake-Mistake apparent from record-Bad and doubtful debts-Assessing Officer giving effect to the order of the Appellate Tribunal and allowing the bad and doubtful-Rectification of reassessment order on same issue is not permissible. [S. 36(1)(viia) 148, 254(1)]

S. 153A : Assessment–Search-Appellate Tribunal has the power to admit additional legal grounds, which goes to root of the matter-No notice was issued to the assessee-Order was quashed. [S. 143(3), 153C, 254(1)]

S. 148 : Reassessment-Notice-Factum of death of assessee intimated to department much prior to issue of notice-Notice issued in name of deceased- Notice not valid. [S. 147]

S. 147 : Reassessment -Not objecting to initiation of reassessment proceedings-Not precluded from challenging validity of reassessment before appellate forums-Reassessment is held to be bad in law. [S. 80IB(10), 148]

S. 145 : Method of accounting-Project Completion method-Shifting gross sales receipts to previous year in which sale deeds executed without shifting expenditure incurred in connection therewith- Violation of Accounting Standard 1-Receipts rightly taxed by Commissioner (Appeals) in later years-No contravention of Rule 46A. [S. 145(2)]

S. 145 : Method of accounting-Accrual of income-Interest-Non-performing assets-Deletion of addition is held to be justified. [S. 4 , 5]

S. 143(3) : Assessment-Income from undisclosed Sources-Difference in stock-Books of account not rejected-Reconciliation of stock filed-Addition is held to be not valid. [S. 69, 132]

S. 143(3) : Assessment-Malmanagement company-Sponsorship and promotional income-Power and fuel Charges-Marketing income considered net of expenses and not separately credited to profit and loss account-Addition is held to be not valid-Security charges, matter remanded. [S. 28(i)]

S. 143(3) : Assessment-Amalgamation of Companies-Assessing Officer required to take successor entity on record and authorised representative required to file Power of Attorney duly authorised by amalgamated entity-Assessment made on non existent entity void ab-initio.