S. 194C : Deduction at source-Contractors-Provision does not contemplate existence of contractual relationship between person responsible for paying and contractor-Existence of contract can be an arrangement which contractor had with payer-No discretion in payer to examine or contemplate chargeability of payment to tax-Payments of external development charges to Urban Development Authority of State Government under direction of Directorate of town and country planning-Absence of formal contract between authority and department does not absolve assessee from liability to deduct tax at source-State Government-Immunity from taxation-Statutory authority established by an enactment of State legislature-Not a Government-Does not have immunity from Union taxation-Penalty-Interest-Reasonable cause-Taxability position remaining unclear-Directions issued accordingly-Reassessment-Notice-Failure to deduct tax at source on payment to statutory authority-Notice based on issue of applicability of Section 194C-Notice and order is set aside. [S. 147, 148,190, 196(1) 196(3) 197, 197A, 201, 221, 271C, 273B, Art. 226, 289

S. 154 : Rectification of mistake-Mistake apparent from the record-Refund-Interest-Adjustment of refund-Order giving effect to court order-Quashing of reassessment proceedings-Pendency of rectification application-Directions issued to Assessing Officer.[S. 148, 237, Art. 226]

S. 154 : Rectification of mistake-Mistake apparent from the record-Deduction of tax at source-Failure by payer to deposit tax deducted-No recovery towards tax deducted at source can be made from assessee-Recovery proceedings can only be initiated against deductor-Assessee entitled to refund. [S. 194, 205, 237, Form No. 26AS, Art. 226]

S. 153C : Assessment-Income of any other person-Search-Failure to appear and make submissions on merits-Court will not examine documents to see id they were incriminating-Order of High Court dismissing the writ petition is affirmed-SLP is dismissed.[S. 264, Art. 136]

S. 153A: Assessment-Search-Elections notified-Applicable only where seized assets or requisitioned are in any manner connected with ongoing Assembly or Parliamentary Election-Seizure of cash by Tamil Nadu State Surveillance team after Tamil Nadu State Assembly Election model code of conduct was in force-Exception is not applicable-Assessee and its president are not excluded from purview of proceedings reassessment.[S.131(IA), 147, 148, 153C,ITR, 112F, Art. 226]

S. 153A: Assessment-Search-Limitation-Direction is issued to refund the entire seized cash with interest-Reassessment notice is quashed. [S. 132A, 132B (4), 147, 148, 153B, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Res Judicata-Notice on basis of issues decided favourably in earlier years-Notice and order disposing the objection is quashed. [S.148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice u/s 148A(b) issued without approval from specified authority-Held, order u/s 148(d) neither a final order nor any demand arose from it-Liberty to assesee to raise any point of merit-Writ petition disposed in favor of Revenue. [S. 148, 148A(b) 148A(d), 151, Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Cash credit-Non-speaking order-Survey by OSBCPL indicated that assessee advanced cash loan and received interest-letter of issuance of a DIN No. to the notice issued-Held, Mandatory to follow procedure u/s 148, [S. 68, 133A, 148, 148A(b), 148A (d)) Art. 226]

S. 148 : Reassessment-Amalgamation-Notice issued to non existing company-Non-est and void. [S. 147, Art. 226]