S. 194J : Deduction at source-Fees for professional or technical services-Foreign agents-No business connection-Not performed any job /operation in India-Not liable to deduct tax at source-OECD Model convention-art.12-Reimbursement of expenses-Not chargeable to tax-Not liable to deduct tax at source. [ S. 5(2)(b), 9(1)(vii), Explanation, 195, 201(1), 201(IA), 204]

S. 164 : Representative assessees-Charge of tax-Beneficiaries unknown-Violation of section 13-Trust has to be taxed at maximum marginal rate under section. 164 (2) on its income. [ S.11, 13(1)(c), 13(2), 164 (2)]

S. 154 : Rectification of mistake-Mistake apparent from the record-Deferred revenue expenditure-Intangible assets-Book profit-Grants given-The Assessing Officer is directed to allow the rectification application.[ S. 37(1)115JB]

S. 153C : Assessment-Income of any other person-Search-Undisclosed income-Ikarnama (Agreement)-Matter remanded to the Assessing Officer. [ S.68]

S. 153A : Assessment-Search-Satisfaction-Computation of six. Assessment years-Absence of notice under section 153C-Actual date of receipts of books of account-Non issue of notice under section 153C-Within period of six assessment years-Not procedural irregularity-Jurisdictional illegality-Not curable provision. [ S. 132 143(3) 153C, 292B]

S. 153A : Assessment-Search-Abated assessment-Addition is justified though no incriminating material is found.[ S. 132]

S. 153A : Assessment-Search-Document Identification Number (DIN)-Assessment can be said to be made only when DIN is quoted on order before it is signed-DIN was not signed before assessment order is signed-Order is non-est-Service of incomplete assessment order on ITBA may be a case of non-service of order; assessment order does not become void for that reason. [ S. 143(3), 153]

S. 153A : Assessment-Search-Document found in the course of search-Presumption cannot be extended to material found at the place of somebody else-Assessment should have been under section 153C and not under section 153A-Undisclosed income-No incriminating material-Deletion of addition is affirmed. [ S. 132(4), 153C]

S. 153A : Assessment-Search-On money-Contents of the WhatsApp amongst partners-Statement of partner-Huge gap between date of communication and sale of flats-Deletion of addition is affirmed-Undisclosed income-On money-addition is sustained to the extent of 10 percent of on-money.[ S. 132]

S. 153A : Assessment-Search-Pendrive-Investigation agency only obtained a certificate about details of pen drive and person in whose custody it was seized and except those details nothing was there in certificate-Certificate was not completely filled up by revenue authorities-Four conditions stipulated in section 65B(2) i.e., (a) to (d) along with section 65B(4) of Indian Evidence Act, 1872 were not followed while obtaining certificate-Certificate is not a valid certificate in eyes of law-Pendrive could not be considered as admissible evidence as per provisions of section 65B of Indian Evidence Act. [ S. 132, Indian Evidence, Act 1872, S. 65B(2), 65B(4)]