S. 244 : Refund-Interest on refunds-Not entitle to interest at the rate of 18 per ccent-Salary paid in arrears or in advance-Refundable amount-Relief under section 89 is to be considered at time of calculating payable amount of tax there is no provision in Act to refund amount of relief granted under section 89 as it is [. S. 89(1), 237, Art. 226]

S. 243 : Refund-Interest on delayed refunds-Failure to grant interest-Strictures-Interest being paid in view of delay by department and officers did not realize that it was a public money that was used to pay interest and an effort should be made to save this public money-Failure to pay same would be viewed as a wilful disobedience of orders and may lead to contempt proceedings. [Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Stay of recovery-Re-agitate issue before High Court-Writ petition is dismissed. [S. 226(3), Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Pendency of appeal before CIT(A)-Commissioner (Appeals) is directed to decide appeal expeditiously without insisting on recovery of demand and till pendency of appeal demand shall be deemed to be stayed without depositing pre-deposit of 20 per cent. [S. 250, Art. 226]

S. 197 : Deduction at source-Certificate for lower rate-Income deemed to accrue or arise in India-Fees for technical services-Order denying Nil TDS certificate is quashed and set aside-Matter remanded-DTAA-India-Ireland [S.9(1)(vii), art. 12]

S. 195A : Deduction at source-Net of tax-Technical services-Income deemed to accrue or arise in India-Royalty-UK based university-Agreed to bear Indian taxes-Required to gross-up amount of fees for technical services (FTS) paid to university, for purpose of deducting TDS under India-UK DTAA-SLP dismissed as withdrawn-DTAA-India-UK [S.9(1)(vi), 9(1(vii), art. 12]

S. 194I : Deduction at source-Rent-Agreement with State Government for Development-External development charges-Not in the nature of rent-Tax not deductible at source on such charges.-Order of High Court is affirmed-SLP of Revenue is dismissed. [S. 201(1), 201(IA), Art. 136]

S. 194H : Deduction at source-Commission or brokerage-Distributors-Payment from distributor had no link with further sale made by distributor, said payment could not be treated as commission or brokerage as described in Explanation to section 194H-SLP of Revenue is dismissed.[Art. 136]

S. 158BD : Block assessment-Undisclosed income of any other person-Satisfaction note is sine qua non and must be prepared by Assessing Officer who has jurisdiction over such other person-Assessment order is illegal-Additions confirmed by the Tribunal is deleted. [S. 131, 153C, 260A]

S. 153B : Assessment-Search and seizure-Time limit-Revision-Conclusion of search-Locker-Last panchanamas-No seizure-Strict interpretation of statutes-Strict rule of interpretation-Not barred by limitation-Reserving the assessee to raise contentions regarding jurisdiction error vis-a-vis limitation period before appropriate authority despite order passed against assessee. [S. 132, 263, Art. 136]