S. 195 : Deduction at source-Non-resident-Social Security contribution, Insurance, Relocation cost, etc., Reimbursement cost-Not fee for technical services-Not liable to deduct tax at source-Administration fee liable to deduct tax at source-DTAA-India-Swiss Confederation. [S. 9(1)(vii), Art. 12(4)]

S. 195 : Deduction at source-Non-resident-Foreign Institutional investor-Rate of tax-Non-convertible debenture-Liable to tax at 15 %-Liable to withhold tax at the rate of 15%-DTAA-India-Singapore. [S. 115AD, Art. 11(2)(b)]

S. 154 : Rectification of mistake-Interest on refund of tax deducted at source-Directions issued to consider pending applications. [S. 237, 244A, Art. 226

S. 153 : Assessment-Limitation-Direction-Court remitting matter to Assessing Officer asking him to give opportunity to be heard-Not a direction-No exclusion of any time in computing limitation-Draft assessment order is beyond period of limitation-Order of Tribunal is affirmed. [S. 92C, 144C, 153(3)]

S. 148 : Reassessment-Amalgamation Of Companies-Intimation was conveyed to the revenue-Notice in name of non-existing entity-Not curable defect-Notice is void. [S. 147, 292B, Art. 226]

S. 147 : Reassessment-Loss-Carry forward and set off-Amalgamation of companies-Change of opinion-Reassessment was held to be not valid. [S. 72A(1)(a), 148, Art. 226]

S. 147 : Reassessment-No tangible material-Sanction for notice was accorded mechanically-Breach of principle of natural justice-Share capital-Share premium-Notice was not valid-Existence of alternative remedy is not an absolute bar-Notice was quashed. [S. 148, Art. 226]

S. 147 : Reassessment-Non-compere fee-Failure to disclose material facts-Notice for reassessment is held to be valid. [S. 148, Art. 226]

S. 147 : Reassessment-Deduction allowed in part during original assessment-Pendency of appeal before Appellate Tribunal-Reassessment proceedings cannot be resorted to in respect of income which is the subject matter of an appeal, reference or revision. [S. 80IA, 148, 253, Art. 226]

S. 147 : Reassessment-With in four years-Notice alleging failure to file the return-Acknowledgement for return filed was produced-Approval was not taken-Notice and order rejecting objections was Set aside- Cost of Rs 20,00 , was imposed on the Revenue . [S. 139, 148, Art. 226]