S. 225 : Collection and recovery-Stay of proceedings-20 percent not a pre-requisite for all appeals-Prima facie case, the balance of convenience, and irreparable injury while disposing of the stay application-stay order is set aside, and the matter is remanded for fresh adjudication after granting an opportunity to be heard. [S. 220, Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Pendency of appeal before Commissioner (Appeals)-Refund-Assessee was directed to approach appropriate authority under section 220(6) by filing stay application pending appeal. [S. 220(6), 225,246A, Art. 226]

S. 220 : Collection and recovery-Assessee deemed in default-Stay-Financial hardship-Rejection of application without reasoning-Remanded back to Principal Commissioner to reconsider issue and pass an appropriate order after granting an opportunity of hearing to assessee. [S. 132, Art. 226]

S. 195 : Deduction at source-Non-resident-Other sums-Commission earned by non-resident agent carrying on business of selling Indian goods outside India could not be said to be income which had accrued and/or arisen in India and, thus, assessee was not liable to deduct TDS on payment of such commission to foreign agents.[S. 40(a)(i)]

S. 194H : Deduction at source-Commission or brokerage-Discounts given by assessee-telecommunication Company on the sale of prepaid SIM cards to distributors-SLP admitted.

S. 194C : Deduction at source-Contractors-Reimbursement of expenditure in absence of evidence-Liable to deduct tax at source [S. 40(a)(ic)]

S. 179 : Private company-Liability of directors-No liability if the director takes steps by filing an appeal before CIT (A)-Order was quashed and set aside. [S. 156, 222,226(3), Art. 226]

S. 153C: Assessment-Income of any other person-Search and seizure-Document-without further investigation-No addition when the document is in doubt. [S. 132]

S. 149: Reassessment-Time limit for notice-Notice issued beyond six years after the end of the relevant assessment year-Notice issued without withdrawing the first notice dated 31-3-2021-Order is bad in law.[S. 148, 148A, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Income deemed to accrue or arise in India-Royalty-Fees for technical services-Tax residency certificate-Reply filed by the assessee was had not been properly considered-Orders set aside-DTAA-India-Singapore-USA [S.9(1)(vi), 9(1)(vii),148A(b), 148A(d), Art. 12, Art, 226]