“Section 197(2)”

Supplementary commission forional or extra services does not fall within the ambit of Section 194H of the Income Tax Act, 1961. This may affect the applicability of certificates issued under Section 197.

Sanction for prosecution under Section 197 of the Code of Criminal Procedure is required for public servants who were or are in service, distinguishing it from Section 19 of the Prevention of Corruption Act, which does not require sanction for those who have ceased to be public servants.

Profits attributable to a Permanent Establishment (PE) in India can be conservatively estimated, such as by applying a percentage of global profits to Indian sales, when the PE's activities in India are minimal.

Part reimbursement of expenses does not constitute income if the services rendered are under the direct control and supervision of the recipient.

The principle of mutuality applies when there is a complete identity between contributors and participators, and their actions are in furtherance of the association's mandate, with no element of profit for the contributors.

The time limit for filing Form 67 to claim foreign tax credit is directory, not mandatory. If no negative consequences are contemplated for non-adherence, the provision is considered directory.

Disallowance under section 40(a)(ia) for non-deduction of TDS on rent or interest payments is deleted if the recipient has furnished Form 15G, as this indicates no tax was deductible at source or tax was not required to be deducted.

Amounts held in a stale draft account cannot be treated as income of the assessee.