S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Contradiction in earlier order-No error apparent on record-Tribunal wrongly recalled the order-Failure by Tribunal to consider applicability of explanation to Section 271(1) (c)-Rectification is held to be not valid. [S. 271(1)(c)]

S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Limitation-Actual date of receipt of order of Tribunal. [S. 253, 268]

S. 254(1) : Appellate Tribunal-Power-Order of remand case is not valid-Remand without considering additional grounds is held to be not valid.

S. 254(1) : Appellate Tribunal-Duties-Telescoping of expenses-Benefit of matching principle-Appeal of revenue-Contention not considered by Tribunal-Matter remanded to Tribunal. [S. 40A(3) 132, 153A, 253]

S. 245R : Advance rulings-Questions raised in application pending before Income-Tax Authority for different years-Application not maintainable. [S. 245R(2)]

S. 245R : Advance rulings-Applicant is not found to be real owner of the transactions-Transactions were designed prima facie for avoidance of tax.-Application is rejected-DTAA-India-Israel. [S. 9(1)(i), 9(1)(vi), 9(1)(vii), 245N(a)(ii), 245R(2)]

S. 245C : Settlement Commission-Full and true disclosure of income-Not disclosing the income discovered during search-Acceptance of application is held to be not valid-Writ petition is held to be maintainable-Order is held to be perverse. [S. 132, 153A, 245D, Art. 226]

S. 201 : Deduction at source-Failure to deduct or pay-Mere entries in accounts-No accrual of income-Not liable to deduct tax at source. [S. 40(a)(i), 40(a)(ia), 192, 194C, 201(IA)

S. 197 : Deduction at source-Certificate for lower rate-Double taxation Avoidance Agreement-Protocol-Common interpretation-Deduction of tax at source-Withholding rate tax in respect of dividend would be 5 percent-DTAA-India-Netherland. [S. 90, 195, Art. 226]

S. 195 : Deduction at source-Non-resident-Agreement with Indian Import of cars as completely built up units on principal to principal basis-Title and risk in goods transferred at port of delivery, payment made outside India and transaction complete outside India-No business connection-Not liable to deduct tax at source-DTAA-India-Japan. [S. 9(1)(i), 195, Art. 5(1)(9)]