S. 194A: Deduction at source-Interest other than interest on securities-Payment of interest by co-operative bank to other cooperative societies-the exemption for deducting tax at source from the payment of interest is only up to Rs. 10,000-The assessee was liable to deduct TDS from payment of interest above this threshold. [S.194A(3)(v), 201(1)]

S. 153D: Assessment-Search-Approval-The approval should not be rubber-stamping and a mere factual formality-Assessment was quashed. [S. 132, 153A, 153B]

S. 153D: Assessment-Search-Approval-Manual of Office Procedure issued by the CBDT in February 2023 was not followed-Separate approval for each assessment year was not obtained-Approval granted is mechanical in manner and without application of mind by the approving authority-Order was quashed.[S. 119, 153C]

S. 153C: Assessment-Income of any other person-Search-Recording of satisfaction-The AO has recorded the satisfaction not as per the statutory convention-The entire assessment is vitiated and bad in law-Addition made on presumption was deleted. [S. 132]

S. 153C : Assessment-Income of any other person-Search-Seized documents-Subsequent exchange agreement-Addition was deleted. [S. 68, 69]

S. 153C: Assessment-Income of any other person-Search-Satisfaction note-Required to be recorded for each assessment year-Consolidated satisfaction note recorded for different assessment years-Bad in law-Approval-Mechanical manner-Order quashed. [S. 153D]

S. 153C: Assessment-Income of any other person-Search-Undisclosed income-Noting loose sheet-Seized from third party-Addition was deleted. [S. 132(4) 292C, Indian Evidence Act, S. 114]

S. 153A: Assessment-Search-Undisclosed income-Manufacturing facility of the assessee does not make it feasible for packaging of the products in small packets-First appellate authority has rightly appreciated the veracity of the evidence furnished by the assessee after verification-Input-output ratio-Order of CIT(A) was affirmed.[S. 132]

S. 153A: Assessment-Search-Undisclosed income-The assessee received software services, and the consideration paid for such services cannot be disallowed. [S. 37]

S. 147: Reassessment-Search-Incriminating documents-Notice issued on the basis of documents seized from a third party not pertaining to the assessee-Reassessment was quashed. [S. 69, 148, 153C]