S. 281B : Provisional attachment-Mere apprehension that huge demand would be made is not sufficient-Tangible reasons are required-Grant of approval cannot be mechanical-Approval for attachment cannot be given without considering facts. [Art. 226]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-Failure to produce accounts and documents-Admission regarding Foreign Bank account after an investigation by department-Revised return was filed after issue of notice-Failure to disclose foreign account opened in year 1991 when the assessee was 55 years of age-Cannot take benefit of circular recommending any prosecution where the assessee is aged 70 years or more at time of offence-Launching of prosecution is justified. [S. 132, 153A, 271, 271(1)(b), 274, 276C(1), 276D, 277, Code of Criminal Procedure, 1973, S. 245(2), Central Board Of Direct Taxes Instruction No. 5051, Dated 7-2-1991]

S. 275 : Penalty-Bar of limitation-Limitation-Limitation starts from the date of assessment when the Assessing Officer initiates penalty proceedings and not from the date of sanction for penalty proceedings. [S. 271D, 275(1)(c)]

S. 260A : Appeal-High Court-International transactions-Arm’s length price-Comparable-Question of fact. [S. 92C]

S. 234E : Fee-Default in furnishing the statements-Levy of the late fee applicable only from 1-6-2015. [S. 200A(1), Art. 226]

S 226 : Collection and recovery-Modes of recovery-Pendency of appeal before CIT(A)-Deduction of tax at source-Failure to consider prima facie case-Payment of 20 per cent. of disputed tax demand is not a prerequisite for a stay of demand-Order set aside and matter remanded to Commissioner (IT) to consider afresh [S. 201(1), 201(IA), 246A, Art. 226]

S. 226 : Collection and recovery-Modes of recovery-Stay of demand-Commissioner (Appeals)-High-pitched assessment-Rejection of stay application without considering the additional evidence-Held to be not justified. [S. 10(34), 246A, 251, Rule, 46A Art. 226]

S. 197 : Deduction at source-Certificate for a lower rate-Payments to Non-Resident-Fees for technical services-No article contained in double taxation avoidance agreement-Department directed to issue a certificate at withholding rate of four Per Cent-Contentions of parties left open-DTAA-India-UAE. [Art. 226]

S. 201 : Deduction at source-Failure to deduct or pay-Interest for delay in remitting tax deducted at source-No liability for interest if tax is not deductible at source. [S. 2(14), 201(IA), Art. 226]

S. 158BD : Block assessment-Undisclosed income of any other person-Search and seizure-Delay in filing of returns-Interest leviable-Assessment of third person notice under section 158BD is sufficient-Not necessary to issue separate notice u/s. 158BC of the Act. [S. 140A(1), 158BC, 158BFA(1)]