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]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Assessing Officer issued on assessee notices under section 148 dated 8-4-2021 seeking to reopen assessment for assessment years 2015-16 and 2016-17-Mandatory procedure of a prior inquiry under section 148A had not been followed-notices were unsustainable in law and quashed-Sanction-Sanction of Additional Commissioner and not only from Principal Chief Commissioner-Notice was quashed. [S. 148, 151, Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Entry operator-Monetary limit of less than 50 lakhs-Subsequent information-Writ petition was dismissed.[S. 148, 148A(b), 148A(d), Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Accommodation entries-No reply was filed-Disputed facts-Writ petition was dismissed.[S.133(6) 148A(b), Art. 226]