“Section 190(3)”

Interest levied under Section 201(1A) for delayed remittance of Tax Deducted at Source (TDS) is compensatory in nature, not penal. It is a distinct provision for delayed remittance, similar to interest paid by Revenue on refunds.

An assessment cannot be reopened merely on the basis of a change of opinion by the Assessing Officer. There must be new tangible material to justify reassessment.

Where the recipient of income is not liable to pay tax in India, the payer has no obligation to deduct tax at source. Consequently, no disallowance under section 40(a)(i) can be made for failure to deduct such tax.

An assessment order dispatched after the prescribed time limit is time-barred and void, even if the dispatch date is before the period of limitation for service.

An ex-parte statement recorded under section 131 cannot be used against an assessee without giving them an opportunity to present rebuttal evidence, as doing so violates the principles of natural justice and vitiates the assessment order.

Evidence or material adduced by an assessee cannot be rejected by the Assessing Officer without conducting an enquiry into its particulars. The scope of this rule does not extend to situations where material implicates the assessee in a collusive arrangement.

Income diverted at source by an overriding title, such as a legal obligation to pay erstwhile partners for work done, is not taxable in the hands of the firm.

Expenditure claimed under section 10(23C) must be actual expenditure made during the year to be treated as an application, and provisions booked by the assessee cannot be allowed as such.