S. 244A : Refunds-Interest on refunds-Since the refund was due to the assessee pursuant to rectification carried out u/s. 154 and arising out of the tax deducted at source upto 31.03.2017 the interest was to be paid to the assessee for period from 1.4.2017 to the date of granting refund. [S. 154]

S. 201: Deduction at source-Failure to deduct or pay-Assessee in default-Reasonable cause-No specified time limit for initiating proceedings under section 201(1) and 201(1A) in cases involving non-resident payees. [S. 9(1)(vi), 201(1), 201(IA)]

S. 201: Deduction at source-Failure to deduct or pay-Assessee in default-Non-deduction of TDS on property purchases-Benefit of First Proviso-Burden of proof on assessee-Non-filing of Form 26A or supporting CA certificate-Interest under Section 201(1A) applicable until seller’s tax filing-Penalty imposed for non-deduction of TDS [S. 194IA,201(1),201(IA), 271C, Form No 26A]

S. 195: Deduction at source-Non-resident-Other sums-TDS on sales commission and sales promotion expenses paid to non-residents-No TDS deductible if non-resident payee does not have a permanent establishment or business connection in India-No tax liability under the Act or DTAA-Disallowance of expenses deleted [S. 5(2)(b), 9(1)(i), 40(a)(ia) 194H]

S. 154 : Rectification of mistake-Mistake apparent from the record-Source of investment-Accepted in original assessment proceedings-Change of opinion is not possible.

S. 153D: Assessment-Search-Approval granted by Joint Commissioner of Income-tax in the case of 49 assessees on the same date on which draft assessment order was passed by the AO-Non application of mind-Assessment order is invalid-CBDT Circular no. 3 of 2008 dated 12.3.2008.[S. 132, 153A]

S. 153C : Assessment-Income of any other person-Search-Satisfaction note-Date of satisfaction note is to be reckoned as date of handing over of materials for purpose of assumption of jurisdiction-Time limit of calculating six years was to be calculated from this date-Assessment year 2008-09 is time barred-No incriminating documents-Addition is deleted. [S. 68, 132]

S. 153C : Assessment-Income of any other person-Search-No incriminating material is found-Addition is not valid [S.132, 153A]

S. 153A: Assessment-Search-Unexplained expenditure-Payment of commission-Bogus sales-Gross profit offered to tax-Gross profit is available to set off-Unaccounted advances paid to employees-Only remaining amount is taxable-Stock-Valuation at average rate of method is acceptable-Addition is deleted-Undisclosed income is accepted-Further addition towards purchases is not justified. [S. 69, 69C, 132, 133]

S. 153A-Assessment-Search-Unabated assessment-No incriminating material-Addition is not valid.[S. 132]