S. 201 : Deduction at source-Failure to deduct or pay-Time limit for passing order–Amendment by Finance Act, 2014 is only procedural–Order has been passed within seven years-Order within limitation. [S. 2(22)(e), 194, 201(3)]

S. 199 : Deduction at source–Credit to tax deducted–Point in time –Credit in the year in which income is assessable-TDS credit is allowed. [R. 37BA]

S. 195 : Deduction at source-Non-resident-Other sums-Payment for purchase of software was in the nature of business income, in the absence of PE, tax was not required to be deducted on such payments. [S. 37, 92]

S. 194H : Deduction at source–Bank guarantee commission–No principal-agent relationship–Not liable deduct tax at source. [s. 2(28A) and 194A(3)(iii)]

S. 153A : Assessment-Search or requisition-Addition made towards undisclosed income on the basis of statement made after the period of search-having no nexus with the incriminating material found during search–not sustainable. [S. 132(4)]

S. 153A : Assessment–Search-Addition to income on account of receipt of share application money and premium-AO not referring to any seized material or other material found during course of search-Addition is unsustainable.

S. 153 : Assessment-Limitation-Capital gains-Reference to valuation officer–No extension of time for assessment as in case of reference under S. 142A-Assessment order to be passed on or before 31.03.2016 whereas the same was passed on 19.05.2016-Order barred by limitation. [S. 45, 50C, 55A, 142A]

S. 151 : Reassessment-Sanction for issue of notice-Approving authorities giving approval in mechanical manner-Reassessment invalid-Department failing to bring on record any evidence of income earned by assessee-Entire amount of doubtful transactions added as assessee’s additional income-Impermissible. [S. 147, 148]

S. 147 : Reassessment–Information obtained from the sales tax department–No independent enquiry or application of mind-Reassessment invalid-Assessment–Notice-Issuance of notice u/s. 143(2) is mandatory – Failure renders the reassessment invalid [S. 69C, 143(2), 148]

S. 147 : Reassessment-Income from other sources–Reassessment proceedings initiated on suspicion-when nothing incriminating was found to suggest that anything over and above Re. 1 per share was paid by assessee-Reassessment is held to be invalid. [S.56(2)(viia), 148]