S. 40(a)(ia) : Amounts not deductible – Deduction at source -Non-resident –Commission- Obligation to deduct tax at source arises only if the sum is chargeable to tax in India , even after insertion of Explanation 2 to S.195(1) by Finance Act 2012 with retrospective effect from 01.04.1962

Wealth-Tax Act, 1957
S.14: Return- Failure to file return on due date – Return was filed pursuant to reassessment notice – liable to pay interest from due date till date of filing of return [ S.17 , 17B ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – No proper enquiry was made in respect of unexplained investment , revision was held to be justified [ S. 69,133(6),143(3) ]

S. 179 : Private company – Liability of directors – Before the Assessing Officer assumed jurisdiction, efforts to recover the tax dues from the company should have failed and such efforts and failure of recovery ought to have been mentioned in the notice, howsoever briefly. No distinction can be made between professional or paid directors and directors holding a large shareholding stake in the company.

S.147: Reassessment-After the expiry of four years- Transfer of shares – There was no failure to disclose material facts -Reassessment is bad in law [ S.148, R.40B ]

S. 143(1) : Assessment – Intimation -Additional tax -Reduction of loss on account of depreciation- Additional tax is held to be not leviable .[ S.143(IA) ]

S. 80P : Co-operative societies – Mere inclusion of name originally and object in bye-laws of society is not conclusive, deduction is eligible .

S. 69B : Amounts of investments not fully disclosed in books of account – Purchase of land – Difference between the amount disclosed and estimate by Assessing Officer cannot be treated as undisclosed . [ S.153A ]

S.68: Cash credits — Deposit in Bank- — Failure to explain the source satisfactorily addition was held to be justified .

S.37(1): Business Expenditure – Commission – Expenditure incurred was reasonably linked with its business which was confirmed by the parties hence allowable as business expenditure