S. 194H : Deduction at source-Commission or brokerage-Agreement with ADPL to develop a plot of land-Association of person (AOP)-Payment was principal to principal basis-Not commission or brokerage-Not liable to deduct tax at source-Order of Tribunal affirmed. [S.133A, 201(1) 201(IA), 260A]

S. 158BD : Block assessment-Undisclosed income of any other person-No recording of satisfaction-Office note cannot be considered as recording of satisfaction-Order of Tribunal quashing the assessment order is affirmed by High Court.[S.132, 158BC, 260A]

S. 154 : Rectification of mistake-Mistake apparent from the record-Designated authority-Certificate in Form 5 was issued–Scope of section 154 was limited to amend any order passed by Assessing Officer under provisions of Income-tax Act, 1961 and it would not be extended to sit over order passed and declaration issued by designated authority under section 5 of DTVSV Act-Order passed by Assessing Officer under section 154 was set aside [S.132(IA), Direct Tax Vivad se Vishwas Act, 2020 Form No 5, Art. 226]

S. 153B : Assessment-Search-Time limit-Proceedings initiated under section 153C-No question of transfer of records seized-Time limit provided by first limb of clause (ii) of third proviso to section 153B(1) shall apply-12 months from end of financial year in which search took place-Time barred-Order quashed.[S. 132, 153C, Art. 226]

S. 153 : Assessment-Reassessment-Limitation-Tribunal, by order dated 31-3-2015, remanded matter to Assessing Officer for de novo consideration-Fresh assessment, as directed by Tribunal, ought to have been completed on or before 31-3-2017 as per sub-section (7) of section 153, as amended by the Finance Act, 2016-Notice dated 6-11-2020 issued by Assessing Officer was barred by limitation. [S. 153(6), 153(7), 254(1), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-A notice which was originally issued under section 148 by Jurisdictional Assessing Officer in terms of old regime and which had been deemed to be issued under section 148A(b) could be continued to be processed by same officer. [S. 148, 148A(b), 148A(d), Art.226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Assessee was given extended time to respond to notice under section 148A(b)-Time was excludable for computing limitation under section 149(1)-Order passed under section 148A(d) was not time-barred. [S. 148A(b), 148A(d), 149(1), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Alternative remedy-Writ is maintainable.[S. 148A(b), 148A(d),246A(1)(b), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notices issued for asst. yr. 2015-16 are held to be invalid as same were issued during the extended period from 1st April, 2021 to 30th June, 2021 under TOLA. [S. 148,149(1),TOLA, S. 3(1), Art. 226]

S 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Notice under section 148 was issued by Jurisdictional Assessing Officer (JAO) instead of Faceless Assessing Officer (FAO)-Notice was quashed-Reopening notice had been issued after more than three years from end of relevant assessment year and thus, reopening without sanction/approval of specified authority in accordance with section 151 was bad in law-Assessee and CBDT entered into a unilateral Advance Pricing Agreement (APA) and assessee filed a modified return as per agreement, since no adverse report was received from TPO which could lead to cancellation of agreement, Assessing Officer had no jurisdiction to make further ALP adjustments and was bound to accept modified return.[S. 92CD, 147, 148, 148A(b), 148A(b) 151, 151A, Art. 226]