S. 206AA : Requirement to furnish Permanent Account Number (PAN) – Provision for deduction at higher rate where recipient fails to provide PAN — Provision cannot override beneficial provisions of DTAAs — Assessee not liable to deduct tax at higher rates in spite of failure by non-resident to furnish PAN [ S.90(2)]

S. 201 : Deduction at source – Failure to deduct or pay – Failure to deduct tax from interest paid on loan — Whether recipient filed its return and declared interest amount in its income and paid due taxes — Assessee to prove before AO — Issue restored to AO to prove this contention. [ S. 194A ,201(IA) ]

S. 148 : Reassessment – Notice — Validity — Amalgamation of companies — Effect — Amalgamating company ceases to exist — Factum of amalgamation brought to notice of AO — Reassessment proceedings against amalgamating company — Not valid [ S.147 ]

S. 145A : Accounting — Valuation of stock — Change in method — Assessee changing method of valuation – Cost or market value whichever is lower method — Changed method consistent with mandatory AS 2 — No need to apply changed method to opening stock of finished goods — Changed method valuation to be applied to all components of inventory

S. 80JJAA : Employment of new workmen —Provisions as existing before 1-4-2016 applicable to earlier years — AO to apply provisions as applicable to each of the earlier years

S. 80P: Co-operative Society —Interest earned from scheduled bank — Not deductible — Net interest from deposits with scheduled bank to be excluded from deduction -Interest earned from Co-operative bank or society— Deduction allowable on net interest- Receipt by society from its members towards form fee — Attributable to and arising from Assessee’s day-to-day activities — Deductible-Standard deduction allowable . [ S.80P(2)(a), 80P(2)(c), 80P(2) (d) ]

S. 69 : Unexplained investments – Undisclosed cash — Money changer — Business requirements — Cash bundles carrying tag of another bank — Common practice — Cash books written day-to-day basis but in practice always a time gap between book entries — No defect pointed out by Assessing Officer in books of account of assessee — addition on basis of suspicion and surmises not justified.

S. 68 : Cash credits — Unsecured loans — Lenders either directors or relatives of directors of Assessee — Assessee furnishing PAN, bank statements, confirmations and copies of income-tax returns of lenders — None of lenders were entry providers — No cash deposited in lenders’ account prior to issuing cheques — Assessee not purchasing cheque by paying cash — Addition unsustainable.