S. 254(1) : Appellate Tribunal – Duties Order –Limitation – Pronouncement – The period of 90 days should be computed by excluding at least the period during which the lockdown due to Covid-19 was in force. [ITATR. 34(5) ]

S. 254(2A): Appellate Tribunal –Stay- Video conferencing – Attachment of bank account lifted and stay against coercive recovery granted. [ S.226 (3) ]

S.241A: Refund- Withholding of refund in certain cases – Satisfaction to be recorded by the AO – The withholding of refund requires the previous approval of the PCIT with reasons to be recorded in writing.- When assessment pursuant to notice under section 143(2) was pending and likelihood of substantial demands upon assessee after completion of scrutiny could not be ruled out, refund claim could not be allowed – When no action is initiated the Court directed the revenue to grant the refunds with in four weeks . [ S.143(1) 143(2) 245 ]

S. 220 : Collection and recovery – Recovery of demand-Gross suppression and misstatement – Sought adjournment before CIT (A) without seeking modification of the Court’s order – Writ dismissed with cost of Rs 5 lakh. [ S.226(3) , Art , 226 ]

S. 199 : Deduction at source – Credit for tax deducted – Deducutor has deducted the tax at source though failed to deposit the tax with the Govt dedcutee cannot be made to suffer- Credit for the tax deducted at source has to be allowed in the hands of the deductee irrespective of whether the same has been deposited by the deductor to the credit of the Central Government or not [ S.205 ]

S. 195 :Deduction at source – Non-resident – The payment by an Indian company to a foreign celebrity (Nicholas Cage) for an appearance by him in Dubai, UAE, in a product launch event for promoting the business of the assessee in India, is taxable as arising from a “business connection” and also under Article 23(1) of Inda-USA tax treaty – Liable to deduct tax at source – DTAA- India -USA [ S.5(2)(b) ,9(1), 115BBA,201, Art .23(1) ]

S. 194E : Deduction at source – Non-resident – Sport person – Sports association – liable to deduct tax at source -The obligation to deduct tax is not affected by the DTAA. [ S. 9(1) ,115BBA ]

S. 147 : Reassessment – Share capital – At the stage of re-opening, only a reason to believe should exist with regard to escapement of income. Definite conclusion would be drawn after raising queries upon the assessee in the light of S. 68 of the Act- Reopening is held to be justified -Sanction -Not required to provide elaborate reasons while approving the sanction -Succession – No requirement to issue two separate notices in name of amalgamated company as successor-in-interest of amalgamating company and to amalgamating company in its individual capacity, [ S.68, 148 ,151 170, Art , 226 ]