S. 271C : Penalty-Failure to deduct at source-Regular delays on part of assessee in depositing tax deducted at source-Levy of penalty is held to be justified. [S. 273B]

S. 263 : Commissioner-Revision of orders prejudicial to revenue– Cash credits- Sale of goods-Produced statement of bank account, copies of bills issued to purchasers as also books of account showing entries of deposits made in bank-Revision is held to be not valid. [S. 68]

S. 251 : Appeal – Commissioner (Appeals)–Powers-Stay was granted by depositing 20% of tax in dispute–High Court reduced to 50 per cent of amount directed in order passed by Commissioner (Appeals) and time to make the payment. [S. 226]

S. 220 : Collection and recovery-Assessee deemed in default–Stay-Issue decided in favour of assessee by CIT(A) in other proceedings-Pendency of appeal before CIT(A)-AO cannot pass the order to deposit 20% of tax in dispute-Stay was granted against recovery of demand.

S. 201 : Deduction at source-Failure to deduct or pay-Rs. 10 Million US Dollars in escrow account- TDS liability-Notices issued under S 201 and 201(1A) would stand stayed during pendency of proceedings.[ S.195, 201(1), 201(IA)]

S. 147 : Reassessment–Second reassessment-High Court set aside the reassessment on one issue–Second reassessment on another ground is held to be not valid. [S. 32, 148]

S. 147 : Reassessment-After the expiry of four years-No failure to disclose all material facts–Reassessment is bad in law. [S.80IB(10), 148]

S. 145 : Method of accounting-Estimating profit rate of 15% per cent which was arrived at with consensus between both parties- Addition is held to be justified.

S. 132(4) : Search and seizure-Statement on oath–Addition made on the basis of statement on oath–Subsequent retraction- Statement recorded during the course of action which was in presence of independent witness has overriding effect over the subsequent retraction- Addition is held to be valid. [S. 131, 132, 292C]

S. 92C : Transfer pricing–Arm’s length price–Interest-11.30 per cent interest paid by assessee to its AE was very much within arm’s length rate- Deletion of addition is held to be valid.