S. 197 : Deduction at source-Certificate for lower rate-Dividend received by a Netherland company from Indian Company-Liable to deduct lower withholding tax rate of 5 per cent instead of 10 per cent-DTAA-India-Netherland. [S. 9(1)(iv), Art. 10, Art. 226]

S. 194J : Deduction at source-Fees for professional or technical services-Payment made for acquiring land for implementation of Bangalore Metro Rail Project-Assessee in default-Failure to deduct tax at source-Matter remanded to the Tribunal to determine whether payments made KIDB included service charges. [S. 201(1), 201(IA)]

S. 194A : Deduction at source-Interest other than interest on securities-Entitlement of interest amount to awarded amount was only Rs. 7000 per claimant. i.e. below threshold limit of Rs. 50,000-Directed to release the amount without deduction of tax at source. [S. 194(3)(ixa)]

S. 153A : Assessment-Search or requisition-No incriminating material-Addition cannot be made. [S. 132]

S. 153A : Assessment-Search or requisition-In the absence of incriminating material merely on the basis of statement recorded of third person without providing an opportunity of cross examination-Addition cannot be made. [S. 132(4), 153C]

S. 153A : Assessment-Search or requisition-Deemed dividend-No incriminating material-Addition cannot be made. [S. 2(22)(e)]

S. 148 : Reassessment-Notice-Constitutional validity-Without following the procedure-Issue of notice is held to be valid. [S. 147, 148A, 149, 151, 151A, 153, 292 Relaxation of Certain Provisions) Act, 2020 (TOLA), S. 3(1) of the Act 38 of 2020, Art. 226]

S. 147 : Reassessment-Unexplained money-Rotation of undisclosed income-FIR filed by CBI-Writ petition was withdrawn. [S. 69A, 148, Art. 226]

S. 147 : Reassessment-With in four years-Deduction at source-Non-resident-Foreign currency loan-Guarantee interest-Material available was not taken in to consideration in original assessment proceedings-Re assessment notice was held to be valid. [S. 148, 195, Art. 226]

S. 147 : Reassessment-With in four years-Income from other sources-Valuation of shares-Order of single judge allowing the writ petition is affirmed. [S. 56(2)(viib), 148, Art. 226]