S. 234B : Interest-Advance tax-Non-Resident-It was obligation of payer to deduct entire tax at source and, assessee was not liable to pay any advance tax and, thus, interest cannot be charged.
S. 234B : Interest-Advance tax-Non-Resident-It was obligation of payer to deduct entire tax at source and, assessee was not liable to pay any advance tax and, thus, interest cannot be charged.
S. 220 : Collection and recovery-Assessee deemed in default-Stay-Pendency of appeal-Direction to deposit 15 % of tax in dispute-Held to be proper. [Art. 226]
S. 194C : Deduction at source-Contractors-Cable operator /MSO/DTH operators-Payment is covered under section 194C and not under section 194J. [S. 194J, 201 (1A)
S. 158BFA : Block assessment-Penalty-Addition to undisclosed income on estimate basis-Deletion of penalty is held to be justified. [S. 158BC, 158BFA(2), 158BGA(2), 271(1)(c)]
S. 153C : Assessment-Income of any other person-Search-Share capital-Deletion of addition is held to be justified when no incriminating material was found in the course of search action. [S. 68]
S. 153C : Assessment-Income of any other person-Initiation of assessment proceedings beyond period of six years from end of financial year in which satisfaction note was recorded by Assessing Officer is held to be not valid. [S. 132]
S. 153C : Assessment-Income of any other person-Search-Not recording satisfaction-Order is illegal and void ab initio. [S. 132, 143 (3)]
S. 153A : Assessment-Search-No incriminating material was found-Addition was held to be not justified. [S. 132]
S. 153A : Assessment-Search-Scope of assessment is limited to assessing only search related income and thereby revenue was denied opportunity of taxing other escaped income that came to notice of Assessing Officer. [S. 132]
S. 153A : Assessment-Search-No fresh material was discovered during search and seizure proceedings-Deletion of addition is held to be justified. [S.132]