S. 194H : Deduction at source-Commission or brokerage-Payment from distributor to assessee had no link with further sale made by distributor-Not liable to deduct tax at source-High Court affirmed the order of the Tribunal-SLP of Revenue is dismissed.[Art. 136]

S. 158BD : Block assessment-Undisclosed income of any other person-Block period 1-4-1996 to 7-5-2002-Assessing Officer of searched person had not recorded the satisfaction for initiation of proceedings-Order is without jurisdiction and unauthorised-No substantial question. of law. [S. 132,144, 153C, 260A]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction note is required to be recorded under section 153C for each assessment year-Consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings.[S. 132, 260A]

S. 153C : Assessment-Income of any other person-Search and seizure-Loose sheet-Not form part of books of account-diaries/loose sheets-Order of Tribunal is affirmed-No substntail question of law.[S. 132, 153A, 260A]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction note is required to be recorded under section 153C for each assessment year and where a consolidated satisfaction note had been recorded for different assessment years, it would vitiate entire assessment proceedings-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 153A, Art. 136]

S. 153C : Assessment-Income of any other person-Search and seizure-Loose sheet-Not form part of books of account-diaries/loose sheets-Order of High Court quashing the addition is affirmed-SLP of Revenue is dismissed.[S. 132, Art. 136]

S. 153A : Assessment-Search or requisition-No incriminating material-Deemed dividend-Deletion of addition is affirmed-No substantial question of law.[S. 2(22)(e), 132, 260A]

S. 153A : Assessment-Search or requisition-Block period of six years-No incriminating material for the relevant assessment year-Order of CIT (A) deleting the addition is affirmed-Order of Tribunal is set aside. [S. 132,260A]

S. 151 : Reassessment-Sanction for issue of notice-Beyond three years-Sanction-Specified Authority-Sanction from Principal Commissioner-Not from Principal Chief Commissioner or Principal Director General or Chief Commissioner or Director General and not under section 151(i)-Prior approval was taken from Principal Commissioner in terms of section 151(i) and not by specified authority under section 151(ii)-Order as well as notice issued under section 148 is bad in law hence quashed and set aside. [S. 148, 148A(b) 148A(d), 151 (i) 151 (ii), Art. 226]

S. 149 : Reassessment-Time limit for notice-Assessing Officer had proceeded without jurisdiction by applying amended provisions of section 149 to case in hand when he issued notice on 25-7-2022 overlooking fact that limitation had already expired on 31-3-2020-Reopening notice issued under section 148 is quashed.[S. 148, 149(1)(b) Art. 226]