S. 9(1) : Income deemed to accrue or arise in India–Business connection-Royalty-Broadcasting services – Subscription-TV channel operator from customers-Receipt was not for transfer of any copyright in literary, artistic or scientific work-Cannot be categorized as royalty income-International taxation-DTAA-India –Singapore [S.9(1) (vii), Copy Right Act 1957, S. 2(y), 14, 37 Art,5, 12]

S. 5 : Scope of total income-Untilized amount on prepaid card at end of year which was treated as advance in balance-sheet and recognized as a revenue receipt in subsequent year, when talk time was actually used or was exhausted-Addition cannot be made – Order of Tribunal is affirmed. [S. 145].

S. 80IC : Special category States -Allocation of expenditure- Remanding the matter to the AO- No substantial question of law . [ S.254(1) ,260A ]

S. 56 : Income from other sources – Valuation of shares- substantiation of the fair market value on the basis of the valuation done by the assessee simply cannot be rejected where the assessee has demonstrated with evidence that the fair market value of the asset is much more than the value shown in the balance sheet. [ S.56(2) (viib) , R.11UA ]

S. 41(1) : Profits chargeable to tax – Remission or cessation of trading liability – Waiver of loan- Cannot be assessed as cessation of liability or as business income .[ S.28(iv) ]

S.28(i): Business income- Client code modification-(CCM )- Shifting of profits- Addition as income on the basis of alleged doubtful transaction is held to be not valid – Deletion of addition b the Tribunal is affirmed . [ S.69, 143(3) ]

Goods and service tax. Finance Act 1994

S. 65: Builder- Collection of non refundable deposits – Not liable to collect service tax .

S. 220 : Collection and recovery – Assessee deemed in default –Pendency of appeal before CIT(A)- Stay of demand – The power of the AO to review the situation every six months, would not authorize him to lift the stay previously granted after full consideration and insist on full payment of tax without the assessee being responsible for delay in disposal of the appeal or any other such similar material change in circumstances.[ S.220(6) , 254(2A) ]

S. 56 : Income from other sources – The assessee has the option to determine the fair market value of shares either under the Discounted cash Flow ( DCF) method or the Net Asset Valuation ( NAV) method. [56(2)(viib ), R. 11UA ]

S. 48: Capital gains- Loan liability of mortgaged property – Doctrine of over-riding title- Not deductible from sale consideration while computing the capital gains .[ S. 4,45, 47(xii), 48(1), SAFAESI ACT ,2002 , S.13 ]