Interpretation of taxing statutes – Constitution of India
Art. 141 : Precedent – SLP dismissal – Non-speaking order -It does not constitute a declaration of law under Article 141 of the Constitution, or attract the doctrine of merger. [ Art, 136 ]

S. 244A: : Refund – Interest on refunds – Unauthorized retention of money by the Department – The Department is directed to pay interest as prescribed .

S. 147: Reassessment – After the expiry of four years- Bogus purchases- Accommodation entries- No failure to disclosure material facts- Change of opinion- Reassessment is held to be bad in law .[ S. 69C ,148 ]

S. 147: Reassessment- After the expiry of four years- Bogus share application money – Shell company – Money received from dubious companies -0 Reassessment is held to be valid – Cost of 2 lakh was imposed on assessee for wasting Court’s time [ S. 68, 143(3) , 148 , Art, 226 ]

S. 139 : Return of income – Delay in filing revised return- Amalgamation – Approval by NCLT – Revised return filed after due date of filing of return is irrelevant- Not required to seek condonation of delay by CBDT [ S. 119(2) (b) , 139 (5) , 170 ]

S. 69C : Unexplained expenditure – Bogus purchases – Sales accepted – The AO is directed to restrict the addition to the extent of lower GP declared by the assessee in respect of bogus purchases as compared to G.P. on normal purchases. [S.68 ]

S. 148 : Reassessment – Notice – Notice sent at address available in PAN database returned – Communication had to be delivered at address of assessee available with banking company – No service of reopening notice – Order making additions unjustified. [S. 147, 282 , R, 127 , Art .226 ]

S. 80HHC : Export business – Interest income assessed as business income is to be included from the profits and gains of business for the purpose of section 80HHC. [S. 80HHC]

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Charges for flight simulator usage and other flight training to cockpit crew and pilots- Not liable to deduct tax at source – DTAA- India-UAE [ S. 9(1)(vi) 195 , Art .12 ]

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Training of pilots and cabin crew – Can not be assessed as fees for technical services or royalties – Not liable to deduct tax at source – OECD Model Convention , Art, 12 [ S.9(1)(vi) , 195 ]