S. 195 :Deduction at source – Non-resident – Other sums – Reimbursement of cost- Matter remanded -DTAA -India -Germany. [S. 9(1)(vii),197, 248]

S. 195: Deduction at source – Non-resident – Other sums – Resident of Canada entitled to benefit under DTAA -DTAA -India -Canada.[S.195(2), Art.]

S.153A: Assessment -Search -Less than 50 lakhs -Assessment beyond six years is bad in law. [S.69, 132]

S.151 : Reassessment – After the expiry of four years – Sanction for issue of notice -The absence of proper authorization from the designated officer renders the notice of reassessment under section 148 null and void from the outset, warranting its dismissal.[S. 127, 147, 148]

S. 147 : Reassessment -Borrowed satisfaction- The reopening of an assessment solely on borrowed satisfaction, devoid of independent scrutiny, lacks validity.[S. 148]

S.147: Reassessment – Information from investigation wing -Borrowed satisfaction -Cash deposits -Reassessment order is set aside. [S. 143(3), 148]

S. 147: Reassessment – After the expiry of four years – No failure to disclose material facts -Reassessment is bad in law. [S. 148 149(1)(b)]

S. 145: Method of accounting -Addition cannot be made on account of Low GP.

S.144C: Reference to dispute resolution panel -Passing draft assessment order -AO passed final assessment order instead of draft assessment order -Invalid order -Order quashed. [S.92CA(3), 144C(4), 153]

S. 144C : Reference to dispute resolution panel -Objection is filed before DRP after due date of time allowed for filing objections- AO should carry proceedings to finalize assessment order as per provisions of section -Assessment order was barred by limitation and treated as void. [S.92CA(3), 144C(4), 153]