S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Inspection charges – Not liable to deduct tax at source -DTAA-India – Indonesia [S.195 , Art. 12 ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Non-resident – Import of coal- No business connection- Income cannot be deemed to have accrued or arose in India in transaction of export of coal to assessee in India- Not liable to deduct tax at source-OECD Model convention , Art 7 . [ S.195, 201 (1) 201(IA) ]

S. 268A : Appeal-Monetary limits-CBDT Circular No. 17/2019, dated 8-8-2019 revising/enhancing minimum threshold limit to tax effect of Rs. 50 lakhs would also be applicable to pending appeals before Tribunal. [S. 253]

S. 251 : Appeal-Commissioner (Appeals)-Power of enhancement Not competent to enhance assessment by taking an income which income was not considered expressly or by necessary implication by AO. [S. 45, 54F, 68, 147]

S. 251 : Appeal-Commissioner (Appeals)–Duties-CIT (A) has to pass a speaking order after appreciation of facts–Matter remanded. [S. 5]

S. 194B : Deduction at source-Winning from lottery–Lucky draw price coupons-Gratuitous distribution without any price being paid by customers-Not lottery–Not liable to deduct tax at source . [S. 2(24 ) (ix), 115BB]

S. 159 : Legal representatives – Assessment-Assessee is not the legal heir of the deceased – Assessment is held to be bad in law .[ S.142(1), Hindu Succession Act, 1956,S 8, 15 ]

S. 68 : Cash credits–AIR information-TDS difference and reconcile income–Addition cannot be made as cash credits. [S. 194J Form, 26AS]

S. 68 : Cash credits–Share transactions–Accommodation entries-Unaccounted money-denial of exemption is held to be justified. [S. 10 (38), 45]

S. 54F : Capital gains-Investment in a residential house–Payments towards purchase of house property-Deduction is available up to date of filing of return of income prescribed u/s. 139(4). [S. 45, 139(1), 139(4)]