S. 243 : Refund-Interest on delayed refunds-Failure to grant interest-Strictures-Interest being paid in view of delay by department and officers did not realize that it was a public money that was used to pay interest and an effort should be made to save this public money-Failure to pay same would be viewed as a wilful disobedience of orders and may lead to contempt proceedings. [Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Stay of recovery-Re-agitate issue before High Court-Writ petition is dismissed. [S. 226(3), Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Pendency of appeal before CIT(A)-Commissioner (Appeals) is directed to decide appeal expeditiously without insisting on recovery of demand and till pendency of appeal demand shall be deemed to be stayed without depositing pre-deposit of 20 per cent. [S. 250, Art. 226]

S. 197 : Deduction at source-Certificate for lower rate-Income deemed to accrue or arise in India-Fees for technical services-Order denying Nil TDS certificate is quashed and set aside-Matter remanded-DTAA-India-Ireland [S.9(1)(vii), art. 12]

S. 195A : Deduction at source-Net of tax-Technical services-Income deemed to accrue or arise in India-Royalty-UK based university-Agreed to bear Indian taxes-Required to gross-up amount of fees for technical services (FTS) paid to university, for purpose of deducting TDS under India-UK DTAA-SLP dismissed as withdrawn-DTAA-India-UK [S.9(1)(vi), 9(1(vii), art. 12]

S. 194I : Deduction at source-Rent-Agreement with State Government for Development-External development charges-Not in the nature of rent-Tax not deductible at source on such charges.-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 201(1), 201(IA), Art. 136]

S. 194H : Deduction at source-Commission or brokerage-Distributors-Payment from distributor had no link with further sale made by distributor, said payment could not be treated as commission or brokerage as described in Explanation to section 194H-SLP of Revenue is dismissed.[Art. 136]

S. 158BD : Block assessment-Undisclosed income of any other person-Satisfaction note is sine qua non and must be prepared by Assessing Officer who has jurisdiction over such other person-Assessment order is illegal-Additions confirmed by the Tribunal is deleted. [S. 131, 153C, 260A]

S. 153B : Assessment-Search and seizure-Time limit-Revision-Conclusion of search-Locker-Last panchanamas-No seizure-Strict interpretation of statutes-Strict rule of interpretation-Not barred by limitation-Reserving the assessee to raise contentions regarding jurisdiction error vis-a-vis limitation period before appropriate authority despite order passed against assessee. [S. 132, 263, Art. 136]

S. 153 : Assessment-Limitation-Tribunal order-and partially remanded-Limitation would commence from the date the date when the Assessing Officer becomes aware of the order of the Tribunal-Order is barred by limitation-Order of Tribunal is affirmed. [S. 153(2A), 254]