S. 194H : Deduction at source–Commission or brokerage-Bank credit card payment–Not liable to deduct tax at source–Lounce charges are covered u/s. 194C and not u/s. 194I of the Act [ S.40(a)(ia), 194I]

S. 179 : Private company-Liability of directors-Recovery of tax— Attachment and sale of immovable property—Limitation—Final order under S. 143(3) and not Intimation u/s. 143(1)-Not barred by limitation. [S. 226, Sch. II, R. 68B, Art, 226]

S. 153C : Assessment-Income of any other person-Search and seizure-Satisfaction of AO of person in respect of whom search conducted that document seized belonged to some other person—Satisfaction not discernible from satisfaction note—Notice is held to be invalid. [S.132, 132(4A), 292C]

S. 153C : Assessment-Income of any other person-Search and seizure –Cash credits – Addition made not on material seized during search – Unsustainable. [S. 68 132, 153A]

S. 151 : Reassessment-Sanction for issue of notice–Notice-Sanction of Additional commissioner instead of Joint Commissioner-Joint Commissioner includes an Additional Commissioner-Notice is held to be valid. [S. 2(28C), 147, 148]

S. 148 : Reassessment–Notice issued in name of legal heirs–Held to be valid. [S. 147]

S. 147 : Reassessment–With in four years-Failure to disclose material facts-Fails to challenge the reopening at the appropriate time before the Court-Not entitled to seek such indulgence, after allowing the Officer to pass the order of assessment-Writ Court cannot sit as an Appellate Authority and decide the merits of the assessment-Writ is held to be not maintainable. [S. 148, Art.226]

S. 147 : Reassessment-Change of opinion-Business expenditure-Technical know how-Depreciation-TP adjustments were made in the original assessment proceedings-Reassessment is held to be not valid. [S. 32(1)(ii), 37(1)]

S. 147 : Reassessment—Change of opinion-Original return processed by intimation No failure to disclose truly and fully all material and no new tangible material available with AO Reassessment is held to be not valid. [S. 143(1), 143(3), 148]

S. 147 : Reassessment-Capital gains-Year of taxability-Transfer of land under Development agreement-Amounts received offered to tax as capital gains and assessed for AY. 1999-2000 up to 2003-04-No adjudication regarding date of effective transfer of land- Reassessment is valid–Tribunal while granting the relief ought to have granted consequential reliefs-AO is directed to give relief for AY.1999-2000 to 2003-04. [S.45, 148, 154, 254(1)]