S. 240 : Refunds-Appeal –Order of Tribunal-Refund denied- Revenue is bound to refund amount to the Assessee with interest as per the provisions of Section 240 and there is no onus on the part of the Assessee to complete any formality for the amount of refund due-Non-functionality of TRACES Portal is not a ground for denying benefit arising out of statutory provision under the Act. [S.201(1)(201(IA), 254(1), Form Non26B, Art. 226]

S. 206AA :Requirement to furnish Permanent Account Number-Provisions of the Income-Tax Act, 1961 cannot override Double Taxation Avoidance Agreement.[S.90, 260A]

S. 201 : Deduction at source-Failure to deduct or pay –Order passed beyond four years-Barred by limitation-Income deemed to accrue or arise in India-Fees for technical services- [S.9(1)(vii), 195 201(1), 201(IA), 260A]

S. 201 : Deduction at source-Failure to deduct or pay –Survey-Direct payment to non-resident-Contractor-Deducted tax at 2 per cent under section 194C-Tribunal is justified in directing Assessing Officer to calculate interest on amount which was paid by contractor as self-assessment tax till date it was deposited and such interest was to be paid by assessee for not deducting tax at source.[S.133A, 194C (4), 195(2), 201(1), 201(IA), 260A]

S. 153C : Assessment-Income of any other person-Search- Reassessment-Time limit for notice-Search conducted in February 2022-Notice under S. 148 dated 30.03.2023 seeking to re-open assessment for A.Y. 2013-14-Relevant A.Y. fell beyond ten years block period set out in S. 153C and thus notice was time barred. [S. 132, 148, 149(1), 153A, Art. 226]

S. 153C: Assessment-Income of any other person-Search-Loose Sheets of papers not shown to form part of books of accounts regularly maintained by assessee would not constitute material evidence-Reasonable opportunity to be provided to assessee before transfer of case in accordance with S. 127-Satisfaction Note to be recorded for each assessment year separately. [S. 127, 132, 153A, Art. 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Material pursuant to a search is relied upon-Assessing Officer is required to follow procedure as contemplated under section 153A, 153B and 153C and it is impermissible for Assessing Officer to continue regular assessment.[S. 132, 133A, 143(3), 153A, 260A]

S. 153A : Assessment-Search or requisition-Search had been conducted on 13-10-2010 and assessments in question were for year 2005-06 to 2007-08 which had been unabated/concluded as on date of search-Assessing Officer is precluded from making any addition to return of income, in absence of incriminating material found as a result of search-The completed/unabated assessments can be reopened by the Assessing Officer in exercise of powers under section 147/148 subject to fulfilment of conditions as envisaged under the said provisions and as may be permissible in law. [S. 132,132A 147, 148, 260A]

S. 153 : Assessment-Limitation-Failure to pass the order within six months from the date of communication of the Tribunal order-Appellate Tribunal restored the matter to the file of AO with directions to comply with the same within 6 months-Assessment order passed beyond the stipulated timeline provided by the ITAT is barred by limitation.[S.153(3), 254(1) Art.226, 265]

S. 151 : Reassessment-Sanction for issue of notice-Mere use of expression Yes I am satisfied could not be considered to be a valid approval-Non application of mind-Reassessment notice is quashed. [S.143(1), 147, 148, Art. 226]