S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Transfer of technical knowledge, experience, skill, Know-how or process or consists of development and transfer of technical plan or design — Payment to us company for providing management, financial, legal, public relations, treasury and risk management services is not for included services —Payment is not taxable in India – When DTAA is more beneficial than income tax-Act DTAA is applicable-DTAA- India – USA- [S.90, art .12]

S.271(1)(c ): Penalty –Concealment – Inadvertently claimed higher rate of 40% depreciation instead of 25%- Bona fide mistake –Deletion of penalty is held to be justified .[ S.32 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –Direction of Commissioner to make certain additions- Tribunal reversed the finding of Commissioner-Question of fact. [ S.260A ]

S. 260A : Appeal – High Court -High Court has power to review- High Court recalled the order and remanded the matter to Tribunal.[S.253]

S. 254(1) : Appellate Tribunal – Powers-Tribunal cannot go beyond question in dispute- When the amounts could not have been added under section 68 , the Tribunal was not competent to make the addition under section 69A -The order of the Tribunal was vitiated in law-Matter remanded to the Tribunal. [ S.68, 69A ]

S. 144 : Best judgment assessment – Low net profit – Tribunal remanded the matter for re examination- No question of law .[ S.260A ]

S. 132(4) : Search and seizure – Statement on oath –Block assessment -Declaration after search has no evidentiary value — Additions cannot be made on basis of such declaration. [ S. 158BC ]

S. 80IA :Industrial undertakings – Prior to assessment Year 1999-2000 benefit under Section 80IA is available without exclusion of deduction Under S.80HHC –Sub –section (9a) with effect from 1-4-1999 is prospective-Circulars binding on revenue -Liberal interpretation — Retrospective operation of provisions. [ S.80HHC, 119 ]

S.68: Cash credits —Evidence of loan and creditworthiness of lenders were furnished –Amount not assessable as cash credits.

S. 56 : Income from other sources –Gifts from relatives-Maternal aunt- Gift need not be on a particular occasion-Addition cannot be made as income from other sources [ S.56 (2)(v)68 ]