S. 194A: Deduction at source-Interest other than interest on securities-Acquisition of loan-Purchased loans (including NCDs, ICDs and term loans)-No part of consideration paid by assessee could be termed as ‘interest’ paid by assessee to transferors-No obligation to deduct tax at source under section 194A. [S. 2(28, 133B(2), 201(1), 201(IA)]

S. 151: Reassessment-Sanction for issue of notice –Notice beyond a period of three years-Assessing Officer was statutorily obligated to have obtained approval from either of the authorities specified under section 151(ii) as per section 151 as amended by Finance Act, 2021, effective from 1-4-2021-Reassessment notice and consequential orders were quashed.[S.68, 148, 147,151 (ii)]

S. 151: Reassessment-Sanction for issue of notice –Notice under section 148 was issued after expiry of three years from the end of the relevant assessment year without approval from the authority prescribed under section 151(ii)-Reassessment proceedings were invalid. [S. 148, 151(ii)]

S. 149: Reassessment-Time limit for notice-Cash deposits-Notice under section 148A in July 2022-Revised notice period for assessment year 2013-14 expired on 26 June 2022-Notice issued on 25 th July 2022 was barred by limitation.[S. 69A, 147, 148, 148A(b), 148A(d)]

S. 147: Reassessment-Purchase of agricultural land-MOU on 21-3-2016-Presented before Joint Sub-Registrar on 24-3-2016, falling in financial year 2015-16 relevant to assessment year 2016-17-Reassessment for the assessment year 2017-18 was not valid. [S. 148 ITATR.27, Registration Act, 1908, S. 47]

S. 147: Reassessment-Unexplained investments-No addition was made on the reasons recorded-Reassessment order was quashed and set aside.[S.50C, 69, 148]

S. 145: Method of accounting-Estimation of profit-Decline in gross profit margin-No specific defects or discrepancies in books of account-Appeal of revenue dismissed.

S. 144C: Reference to dispute resolution panel-Dividend-Rate of tax-Singapore tax resident-Mistakenly offered non-taxable capital gains and excess tax on dividends-Assessing Officer and DRP ignored correction request, citing lack of jurisdiction-Tribunal held that DRP can examine such issues under section 144C(8)-Tribunal restored matter to Assessing Officer to verify and allow relief if admissible-DTAA-India-Singapore [S.9(1)(i) 144C(8), Art.10]

S. 144C: Reference to dispute resolution panel-Amalgamation-Non-existent entity-Draft assessment order was passed in the name of a non-existent entity despite the Assessing Officer having been duly informed of amalgamation-Void-ab-initio. [S. 144C (5),292B]

S. 143(3): Assessment-Limited Scrutiny-Depreciation-Goodwill-Increase in share capital-Assessing Officer could not have enlarged scope of limited scrutiny to full scrutiny without prior approval of Jurisdictional Commissioner-Addition made by Assessing Officer disallowing depreciation on goodwill was quashed.[S. 32, 143(2)]