S. 201 : Deduction at source-Failure to deduct or pay-Short Deduction-Order passed beyond two years from end of financial year in which statements of tax deducted at source filed-Order Barred by imitation-Payment to contractor-Matter remanded. [S. 194C, 194J, 201(1), 201(IA)]

S. 194H : Deduction at source-Commission or brokerage-Payment received by agent-Principal to principal-Expenses on doctors and stockists, dealers and field staff-Not liable to deduct tax at source.

S. 154 : Rectification of mistake-Limitation-Doctrine of merger Notice proposing to rectify Assessing Officer’s order giving effect to order of Tribunal on appeal from order of revision by Commissioner-Limitation to be reckoned from date of original assessment order and not of order giving effect to Tribunal’s order. [S. 80IA, 154(7), 254(1), 263]

S. 153C : Assessment-Income of any other person-Search-Deposit made by members-No incriminating material was found-Addition is held to be not sustainable. [S. 132]

S. 153C : Assessment-Income of any other person-Search Presumption operates only against person from whose possession document found-Loose paper-Statement of person against whom search conducted-Cross examination not allowed-Addition is held to be not justified. [S. 132(4A), 292C]

S. 153A : Assessment-Search-Dumb documents-Addition is held to be bad in law.

S. 153A : Assessment-Search-Dumb documents found inn third party premises-Addition is held to be not valid. [S. 132, 153(1)]

S. 147 : Reassessment-Death of assessee-Notices and reassessment orders passed in name of deceased assessee quoting his Permanent Account Number is held to be not valid. [S.148]

S. 147 : Reassessment-Change of opinion-Full and true disclosure-Reassessment is held to be bad in law. [S. 54EC, 54F, 148]

S. 147 : Reassessment-Income of any other person-Search-Reassessment is not valid when the assessment out have been done under section 153C of the Act as per non obstante provision-Cross examination denied-Addition as cash credit is held to be not justified. [S. 68, 132, 153C]