S 226 : Collection and recovery-Modes of recovery-Pendency of appeal before CIT(A)-Deduction of tax at source-Failure to consider prima facie case-Payment of 20 per cent. of disputed tax demand is not a prerequisite for a stay of demand-Order set aside and matter remanded to Commissioner (IT) to consider afresh [S. 201(1), 201(IA), 246A, Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Stay of demand-Commissioner (Appeals)-High-pitched assessment-Rejection of stay application without considering the additional evidence-Held to be not justified. [S. 10(34), 246A, 251, Rule, 46A Art. 226]

S. 197 : Deduction at source-Certificate for a lower rate-Payments to Non-Resident-Fees for technical services-No article contained in double taxation avoidance agreement-Department directed to issue a certificate at withholding rate of four Per Cent-Contentions of parties left open-DTAA-India-UAE. [Art. 226]

S. 201 : Deduction at source-Failure to deduct or pay-Interest for delay in remitting tax deducted at source-No liability for interest if tax is not deductible at source. [S. 2(14), 201(IA), Art. 226]

S. 158BD : Block assessment-Undisclosed income of any other person-Search and seizure-Delay in filing of returns-Interest leviable-Assessment of third person notice under section 158BD is sufficient-Not necessary to issue separate notice u/s. 158BC of the Act. [S. 140A(1), 158BC, 158BFA(1)]

S. 153C : Assessment-Income of any other person-Search-Incriminating material-Failure to establish how seized documents had nexus with undisclosed Income of assessee-Proceedings initiated was quashed. [S. 132]

S. 151 : Reassessment-Sanction for issue of notice-Approval obtained from additional Commissioner and not from specified authority-Notice was quashed. [S. 147, 148, 151(ii), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Reasons for notice of reassessment and opportunity to be heard were given-Reassessment proceedings valid. [S. 147, 148, 194C, Art, 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Transactions not disclosed in initial notices-Department cannot travel beyond notice-Notice and order set aside. [S. 147, 148, 148A(b), 148A(d), Art. 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-New procedure with effect from 1-4-2021 Notices for prior periods issued without complying with new provision-Notices were quashed. [S. 147, 148,149(1)(b), Taxation and Other Laws (Relaxation and amendment of Certain Provisions) Act, 2020, Art. 226]