S. 195 : Deduction at source-Non-resident-Other sums-Fees for technical services-Make available-Order of Authority for Advance Rulings Ruling that payment income of non-Resident liable for deduction of tax at source is set aside-DTAA-India-UK [S. 9(1)(vii), 245Q, Art. 7, 13]

S. 194H : Deduction at source-Commission or brokerage-Manufacturer of computers and peripherals-Sale of products by distributor at price less than invoice price after products reached distributor and after raising of invoices-Principal to Principal and not that of principal to agent-Assessee is not in default-Order of Tribunal is affirmed.[S. 201(1), 201(IA), 260A]

S. 153D : Assessment-Search-Approval-Order passed without obtaining the prior approval is bad in law-SLP of Revenue is dismissed. [S. 132,153A, 153B, Art. 136]]

S. 153C : Assessment-Income of any other person-Limitation-A composite Satisfaction Note would suffice the requirements of Section 153C of the Act provided it embodied details of the material gathered in the course of the search and pertaining to the AYs forming part of the block as a whole-As long as proceedings are initiated within a reasonable period from the closure of assessment of the searched person, a failure to take immediate action would not be fatal to the assessment-Writ petition is dismissed. [S. 132, 153A, 153B, Art.226]

S. 153A : Assessment-Search-No assessment was pending on the date of search-No incriminating material was found during the search-Fresh material/information received after the date of search would not be sufficient to reopen the assessment under section 153A.[S. 80IAB, 132,143(1), 143(2), 260A]

S. 151 : Reassessment-Sanction for issue of notice-Sanction of specified authority mandatory-Three years from the relevant assessment years-No approval of specified a[S. 147, 148, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Amalgamation-Show-cause notice against non-existent entity non-est-Show-cause notice and subsequent order for issue of notice is set aside.[S. 147, 148, 148A(b) 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Violation of principle of natural justice-Order set aside-Matter remitted to National Faceless Assessment Centre. [S. 144, 144B, 147, 148A(b) 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Investments by Foreign Companies in Shares of their own Indian subsidiaries-Transactions are capital account transactions-No proof of transactions being consequence of round-tripping-Investment in shares capital account transaction not income-Notices and orders set aside. [S. 9(1)(i), 115A, 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Initial notice-Personal hearing-Personal hearing not statutory mandate but discretion of Assessing Officer-Writ petition is dismissed-Assessee can raise contentions in reassessment proceedings-Interpretation of taxing statutes-Legislative intent-Plain language of provision must be given its ordinary meaning.[S. 132, 147, 148, 148A(b),148A(d), Art. 226]