S. 254(1) : Appellate Tribunal-Duties-Telescoping of expenses-Benefit of matching principle-Appeal of revenue-Contention not considered by Tribunal-Matter remanded to Tribunal. [S. 40A(3) 132, 153A, 253]

S. 245R : Advance rulings-Questions raised in application pending before Income-Tax Authority for different years-Application not maintainable. [S. 245R(2)]

S. 245R : Advance rulings-Applicant is not found to be real owner of the transactions-Transactions were designed prima facie for avoidance of tax.-Application is rejected-DTAA-India-Israel. [S. 9(1)(i), 9(1)(vi), 9(1)(vii), 245N(a)(ii), 245R(2)]

S. 245C : Settlement Commission-Full and true disclosure of income-Not disclosing the income discovered during search-Acceptance of application is held to be not valid-Writ petition is held to be maintainable-Order is held to be perverse. [S. 132, 153A, 245D, Art. 226]

S. 201 : Deduction at source-Failure to deduct or pay-Mere entries in accounts-No accrual of income-Not liable to deduct tax at source. [S. 40(a)(i), 40(a)(ia), 192, 194C, 201(IA)

S. 197 : Deduction at source-Certificate for lower rate-Double taxation Avoidance Agreement-Protocol-Common interpretation-Deduction of tax at source-Withholding rate tax in respect of dividend would be 5 percent-DTAA-India-Netherland. [S. 90, 195, Art. 226]

S. 195 : Deduction at source-Non-resident-Agreement with Indian Import of cars as completely built up units on principal to principal basis-Title and risk in goods transferred at port of delivery, payment made outside India and transaction complete outside India-No business connection-Not liable to deduct tax at source-DTAA-India-Japan. [S. 9(1)(i), 195, Art. 5(1)(9)]

S. 192 : Deduction at source-Salary-Provision of residential accommodation by employer-Valuation of perquisite-Residential Accommodation provided to regular and contract employees on collection of licence fee according to area of quarters and commensurate with salary of employee-Perquisite-Liable to deduct tax at source. [S. 15, 17(2), ITR, 1962, R. 3(1) Art. 12, 226]

S. 153A : Assessment-Search-Principle of natural justice must be followed-Notice u/s. 143(2) is not mandatory-Order quashed and set aside. [S. 143(2), 158BC, Art. 226]

S. 153A : Assessment-Search-Block assessment-Failure to hand over seized material by Investigation Officer to Assessing Officer within prescribed time-limit-Notice will not be invalid. [S. 132, 132(9A), 153B, Art. 226]