S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Apportionment of income-MAP proceedings– Appropriate to adopt 7.5 % as adjusted commercial linehaul charges (CLC) / total linehaul charges (TLC) ratio for computing taxable income-DTAA-India-USA. [Art. 8]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection–Cannot be considered as constituting Agency PE of that assessee-DTAA-India–Mauritius. [Art. 5(5), 8]

S. 279 : Offences and prosecutions–Compounding–Review–Compounding fees was levied 5% as treating the same as second application–Review petition was dismissed. [S. 201(1), 276B, 279(2), CPC, S. 114]

S. 271(1)(c) : Penalty–Concealment–Capital gains-Merely because claim is not accepted levy of penalty is held to be not justified. [S. 45, 54EC]

S. 260A : Appeal-High Court-Issue not contested cannot be agitated before the High Court. [S. 37(1)]

S. 245D : Settlement Commission–Full and true disclosure– Additional income disclosed–Justified in holding that there was a full and true disclosure-Writ petition of revenue is dismissed . [S. 133A, 245C, 245D(4), Art. 226]

S. 234A : Interest-Default in furnishing return of income-Waiver of interest–Or otherwise–Delay in filing of return was due to impounding of documents in the course of survey.[S. 234B, 234C, Art. 226]

S. 225 : Collection and recovery-Stay of proceedings–Pendency of appeal–Recovery of penalty is stayed till the disposal of the appeal. [S. 271(1)(c), Art. 226]

S. 221 : Collection and recovery–Penalty-Tax in default –Delay in remitting the Tax deducted at source-Survey – Financial stringency not proved-Levy of penalty is held to be justified. [S. 133A, 201]

S. 197 : Deduction at source-Certificate for lower rate–Application for lower tax deduction is allowed, subject to certain conditions. [S. 194-C, 194-H, 197, 201(1), 201(1A), 264, Art.226]