No penalty is justified for initial non-compliance with a Section 142(1) notice if the taxpayer subsequently makes good the default and the assessment is completed under Section 143(3) after considering all submissions.

Payments towards CAM charges are in the nature of contractual payments for services, not rent for use of premises/equipment. They therefore attract TDS at 2% under Section 194C, not Section 194I.

Rectification is not a substitute for review or reassessment, especially in contentious matters like Section 14A disallowances.

The law does not prohibit all dealings with specified persons; Section 13 only bites if there is actual benefit. Purely facilitating the charitable object, even via related parties, is not disqualifying unless benefit is demonstrated.

Recognizing conflicting views on the computation of “due date”—whether it runs from the month salary is paid or the month salary accrues—the ITAT Delhi remanded the issue back to the AO.

An invalid order cannot give birth to legally valid proceedings. A void reassessment order cannot be the subject matter of revision under Section 263.

Section 56(2)(viib) should not be mechanically invoked in transactions between a wholly-owned subsidiary and its holding company.

The block period of six years for these assessments must start from when the AO of the assessee receives the seized material and records satisfaction, not from the date of the search itself. Once Section 153C is invoked and the block period is determined, any regular assessment proceedings for those years automatically abate. New proceedings, if any, must strictly comply with Section 153C.

The amendment brought by Finance Act, 2014, which replaced the limitation period with a uniform 7 years, is prospective in nature, effective 1 October 2014. For financial years prior to the amendment, including FY 2013–14, the earlier limitation of 2 years (in cases where the TDS statement was filed) continues to apply.