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]

S. 148 : Reassessment-Notice-Amalgamation of companies-Amalgamating company and amalgamated company operating from same address after amalgamation-Provision of Section 170(2) applicable-Participated in the reassessment proceedings-Notice and reassessment proceedings valid. [S. 147, 170(2), Art. 226]

S. 148 : Reassessment-Notice-Assessee has right to raise objections-Duty of Assessing Officer to consider objections-Failure to consider objections-Matter remanded. [S. 147, Art. 226]

S. 148 : Reassessment-Notice-Proper procedure to be adopted-Writ against the notice was dismissed. [S.147, Art. 226]

S. 147 : Reassessment-Information received from Investigation wing-Non application of mind-Sanction not obtained-Notice is held to be not valid. [S. 133A, 148, 151, Art. 226]

S. 147 : Reassessment-After the expiry of four years-Housing projects-No failure to disclose any material facts-Reassessment is not valid. [S. 80IB(10), 148, Art. 226]