S. 201 : Deduction at source-Failure to deduct or pay-Royalties/fees for technical services-Payment made to US based company towards cost reimbursement on which parties had equal right to use and not paid amount to royalty, levy of interest u/s. 201(1A) is unjustified-DTAA-India-USA. [S. 9(1)(vi), 195, 201 (IA), Art, 12]

S. 195 : Deduction at source-Non-resident-Agency Agreement-Principal and agent relationship-Sales commission for services rendered outside India-Not liable to deduct tax at source. [S. 5(2), 9(1)(vii), 40(a)(i)]

S. 194C : Deduction at source-Contractors-Provision is applicable only when assessee has paid or credited any charges covered thereunder-Estimated excessive wastage treated as Making charges-Disallowance cannot be made for failure to deduct tax at source. [S. 40(a)(ia)]

S. 154 : Rectification of mistake apparent on record-No format prescribed for rectification application-A simple letter can be considered as a rectification application even if it does not mention to be a rectification application-substantial justice prevails over technical consideration-Revenue cannot take undue benefit of the negligence of Assessee with regards to his rights-Long term capital gains on sale of property is directed to be excluded. [S. 45].

S. 153C : Assessment-Income of any other person-Search-No incriminating evidence found-Addition cannot be sustained.[S. 132]

S. 153C : Assessment-Income of any other person-Search-Cash Credits-Addition cannot be made in the absence of any incriminating materials found during search-Addition cannot be made without providing copies of statement recorded and an opportunity of cross examination. [S. 68, 132]

S. 153A : Assessment-Search-Valuation report-Valuation report cannot be held to be incriminating material-Addition held to be not valid-DDIT (Inv)/ADIT (Inv) was empowered to make reference to Valuation Officer inserted by section 132(9D) only after 1-4-2017 by an amendment by Finance Act, 2017 [S. 132,132(9D), 142A]

S. 151 : Reassessment-Sanction for issue of notice-Non issuance of notice-Mechanical satisfaction of P without application of mind-Reassessment not sustainable. [S. 69, 147, 148, 282]

S. 151 : Reassessment-Sanction for issue of notice-Satisfaction recorded in a mechanical manner without application of mind-Additional ground Reopening held to be invalid. [S.147, 148, 254 (1)]

S. 148 : Reassessment-Notice-Reasons for reopening not supplied-Directed to supply reasons for reopening and only after disposal of objections, if any, raised, AO would proceed to re compute income of assessee in accordance with law-Matter remanded. [S. 69B, 147]