S. 194H : Deduction at source – Commission or brokerage – Fees for professional or technical services – Discount to prepaid cards to distributors – Principal to principal basis – Roaming arrangement with other distributors – Not liable to deduct tax at source under section 194H or under section 194J -Interest is not leviable [ S.194H , 201 (1) ]

S. 143(3) : Assessment – Search and seizure – Excess consumption – Suppression of receipts –Discounts – Addition is held to be not valid [ S.132A ]

S. 143(1)(a) : Assessment – Intimation – Late filing of return – Denial of exemption – No intimation was given to the assessee, the adjustment was liable to be deleted [ S.80AC, 80IC , 139(4) ,143(1)(a) (v) ]

S. 92C : Transfer pricing – Arm’s length price – Capacity utilisation of comparable – Details not available in public domain — Remanded to the TPO to call for information and decide the issue [ S.133(6) ]

S. 80P : Co-operative societies -Primary agricultural credit Society — Narration in Loan extracts in audit reports is not conclusive- Assessing Officer to examine details of each loan disbursement and determine purpose for which loans disbursed.

S. 80P : Co-operative societies – Agricultural purpose or allied activities- Matter remanded to the AO to examine activities of assessee afresh and determine whether activities in compliance with activities of Co-Operative Society functioning under Kerala Co-Operative Societies Act, 1969 and to grant deduction. [S.80P(2), Kerala Co-operative Societies Act, 1969. ]

S. 80IC : Special category States – Electricity consumption – Not producing toll tax receipt does not make the purchases as bogus- Entitle to deduction.

S. 69C : Unexplained expenditure – Bogus purchases – Sales not doubted – Addition is restricted to 12.5 percent of non -genuine purchases and less gross profit already declared [ S.37(1) ]

S. 68 : Cash credits -Accommodation entries – Pravin Kumar Jain group –Loan confirmation , PAN no, copy of bank account of lender was produced – Submission was filed in pursuance of notice u/s 133(6) of the Act -Deletion of addition is held to be justified [ S.133(6)

S. 68 : Cash credits – Firm — Capital introduction by partners — Addition is held to be not valid – The period during which the lockdown was in force shall stand excluded for the purpose of working out the time limit for pronouncement of orders, as envisaged in rule 34(5) of the Income-tax (Appellate Tribunal) Rules, 1963 .[ S.254(1) , ITAT R.34(5)]