S. 251 : Appeal-Commissioner (Appeals)-Powers-Jurisdiction-Direction of DGIT not to pass the during pendency of explanation-Order passed without following the direction and jurisdiction was set aside. [S. 120, 246A]
S. 251 : Appeal-Commissioner (Appeals)-Powers-Jurisdiction-Direction of DGIT not to pass the during pendency of explanation-Order passed without following the direction and jurisdiction was set aside. [S. 120, 246A]
S. 206AA : Requirement to furnish Permanent Account Number-Double taxation agreement-Provision of 206AA does not override the provision of double taxation agreement-Tax deducted as per the provision of DTAA is held to be valid-DTAA-India-Czech Republic. [S. 90, Art. 12]
S. 194J : Deduction at source-Fees for professional or technical services-Transaction fee paid to stock exchange-Not liable to deduct tax at source.
S. 194IA : Deduction at source-Immoveable property-Joint development agreement-Interest free deposit-No transfer of property-Not liable to deduct tax at source. [S. 2(47)(v), 201, 201A, 203A, Transfer of Property Act, 1882, S. 53A]
S. 194I : Deduction at source-Rent-VSAT and lease line charges to stock exchange-Not liable to deduct tax at source.
S. 194C : Deduction at source-Contractors-Services on a principal-to principal bases-Payment to drivers-Cannot be treated as assessee in default for failure to deduct tax at source. [S. 201(1), 201(A), 204]
S. 154 : Rectification of mistake-Transfer pricing-Adjustment-Order of Tribunal is binding on the Assessing Officer-Rectification of order to make adjustment is beyond jurisdiction and bad in law. [S. 92C]
S. 151 : Reassessment-Sanction for issue of notice-After the expiry of four years-It is mandatory that satisfaction of Pr. CIT / CCIT / PCIT / CIT. [S. 143(3), 147, 148]
S. 147 : Reassessment-Anonymous donation-Notice for under utilisation of income-No addition was made in respect of notice issued-Addition made on account of anonymous donation is held to be without jurisdiction and bad in law. [S. 115BBC, 148]
S. 147 : Reassessment-Cash credits-Bogus accommodation entry-General information-Reassessment is held to be not valid. [S. 68]