S. 194C: Deduction at source-Contractors-Technical services-Processing of milk attracts deduction of tax at source under section 194C at 2 per cent is rightly deducted-Order of Tribunal is affirmed.[S. 40(a)(ia), 194J, 260A]

S. 179 : Private company-Liability of directors-Order against Ex-director of company-No steps were taken to recover dues from the company-Order is set aside. [Art. 226]

S. 176 : Discontinued Business—Company struck off from official register of companies-Reassessment-Directors-Reassessment proceedings against the Directors in case of struck companies. S. 176 is applicable only when the company has discontinued the business. [S. 147, 148, 176(5), 176(7), Companies Act Art. 226]

S. 154 : Rectification of mistake-Mistake apparent from the record-Inadvertently disclosed income in its return-Return was accepted u/s. 139(1)-Rectification is rejected-Tribunal allowing the claim-Dismissing the appeal the Court held that merely because respondent included the income in the return as taxable cannot make it amenable to imposition of tax-DTAA-India-USA [. S. 139(1),143(1), 260A, Art. 14]

S. 153A: Assessment-Search-Assessment prior to search-Order of High Court is affirmed-SLP of Revenue is dismissed.[Art. 136]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Limitation-Notice issued after three years-Barred by limitation-Travel back in time theory unsustainable-That the principle of constructive res judicata was not applicable. The orders passed under section 148A(d) and the consequent notices issued for the assessment years 2016-17 and 2017-18 under the amended provisions of section 148 of the 1961 Act were unsustainable. [S. 148, 148A(b) 148A(d),149, Art. 142, 226]

S. 148A : Reassessment-Conducting inquiry, providing opportunity before issue of notice-Resident of Uganda-Mutual fund investment-Source of investments coming from Non-Resident External Accounts Beyond Reach Of Authorities-No Tangible material for belief that income had escaped assessment-Notice not valid.[S.10(4), 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-No violation of principle of natural justice-Loan transactions-Question of fact-Writ petition is dismissed. [S. 69C, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Matter restored to the AO as the main contention of the assessee that it had not claimed any deduction for such liability was not considered while passing order u/s. 148A (d) of the Act. [S. 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Premature-Before issue of notice u/s 148-Writ petition is dismissed. [S.148, 148A(b), 148A(d), Art. 226]