S. 194C : Deduction at source-Contractors-Project work on ‘Build-Own-Operate-Transfer”-Subsidy-Infusion of equity capital as measure of financial support through contractual obligation cannot be treated as payment for work undertaken-Provisions of section is 194C not applicable.[S. 260A]

S. 179: Private company-Liability of directors-Order passed upon deceased assessee-director raising tax demand of Company-Company was under CIRP under Insolvency and Bankruptcy Code (IBC)-No efforts by AO in compliance to Section 179(1)-Proceedings commenced upon the assessee-director quashed and set aside.(Art. 226]

S. 158BD : Block assessment-Undisclosed income of any other person-No satisfaction note from the Assessing Officer of the searched person-Initiation is without jurisdiction-Order of Tribunal is affirmed.[S. 260A]

S. 154 : Rectification of mistake-Mistake apparent from the record-Since rectification order was passed three years after framing of original order of assessment,-Pendency of appeal-Rectification order is quashed. [S. 147, 148, Art. 226]

S. 153C: Assessment-Income of any other person-Search-Additions based on a survey conducted in premises of assessee and not based on incriminating material found/seized during search and neither recorded in ‘Satisfaction Note’ during assessment under S. 153C cannot be sustained and deserves to be deleted.[S. 133A, 260A]

S. 153C: Assessment-Income of any other person-Search-Material related to assessee being other person found during search and handed over to AO-Assessment ought to have been made under S. 153C and not S. 143(3) of the Act-Order of Tribunal quashing the addition is affirmed. [S. 143(3), 260A]

S. 153A: Assessment-Search-No incriminating material is found-The Assessing Officer (AO) can only reopen assessments for the block period of six years if incriminating material related to each specific year is found during the search and not otherwise-Order of Tribunal is set aside. [S. 132, 158BB, 260A]

S. 153A: Assessment-Search-Additions unsustainable in the absence of incriminating material for unabated assessments-No addition can be made-Order of Tribunal is affirmed. [S. 132, 133A, 153C, 260A]

S. 153 : Assessment-Reassessment-Limitation-When there is no finding or direction in terms of clause (i) of sub-section (6) of Section 153, the extended time shall be 60 days, as specified in the first proviso to Explanation 1 of Section 153, rather than 12 months-Direction-Inconsequence of-To give effect to-Finding-Assessment order is barred by limitation. [S. 143(3) 144B, 147, 148, 153(3)(ii), 153(6), 260,Income Tax Act, 1922, S. 34(3), Art. 226]

S.151A : Faceless assessment of income escaping assessment-Notices under section 148 must be issued in a faceless manner through automated allocation as per section 151A and the notification dated 29-3-2022. The Jurisdictional Assessing Officer (JAO) lacks the authority to issue such notices, rendering them illegal and invalid. [S. 147, 148, 148A(b), 148A(d), Art. 226]