S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Non-resident-Make available-Cloud-based software-Tax Residency Certificate-The receipts were not chargeable to tax in India as fees for technical services-DTAA-India-USA. [Art. 12(4)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Non-resident-Revenue sharing arrangement-Payments received by foreign associated enterprise from Indian parent under Master Service Agreement not taxable as fees for technical services-Revenue sharing for services jointly rendered to customers-Additions were deleted. [S. 147, 148 ]

S. 271(1)(c): Penalty-Concealment-Legal Representative-Legal heirs are liable for a penalty to the extent of the estate inherited. [S. 159]

S. 270A: Penalty for under-reporting and misreporting of income-Bona fide explanation-Revised computation filed voluntarily before issue of notice-Penalty not leviable.[S. 195, 194LC, 270A(6)(a)]

S. 270A: Penalty for under-reporting and misreporting of income-Wrong claim of exemption under section 10(10AA)-Bona fide legal claim-Penalty deleted. [S. 10(10AA), 270A(9)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Invalid Reassessment-PCIT cannot revise a reassessment order which is itself void for want of proper sanction under section 151-Reassessment without approval of the competent authority is non est. [147, 148, 148A(d), 151(1)), 151(ii)]

S. 253: Appellate Tribunal-Appeals-Respondent can raise jurisdictional ground without filing appeal or cross-objection [S. 254(1), ITAT R. 27]

S. 251: Appeal-Commissioner (Appeals)-Powers-Remand of matter to Assessing Officer-CIT(A) has no power to remand an appeal to the Assessing Officer except in cases covered by the proviso to section 251(1)(a) i.e., where the assessment is framed under section 144. [.S. 201, 250(6), 251(1)(a)]

S. 249: Appeal-Commissioner (Appeals)-Form of appeal and limitation-Condonation of delay-Two PANs allotted to assessee-Proceedings initiated under old PAN-Sufficient cause established-Delay was condoned-Matter remanded. [S. 147, 148A, 144, 249(3)]

S. 234D: Interest on excess refund-Regular assessment completed before 1-6-2003-Consequential order under section 143(3) read with section 254 does not attract interest. [S. 2(40), 143(3), 147, 153A, 254]