S.9(1)(i): Income deemed to accrue or arise in India – Business connection -Profit earned from offshore supply of installation and commissioning activities of equipments relatable to operations carried out in India is held to be taxable since it had supervisory Permanent establishment in India – DTAA- India- China [ Art. 5 ]

S. 4 : Charge of income-tax -Capital or revenue-Book profit – Sales tax subsidy granted by the Government for purpose of setting up or expansion of Mills would be capital receipt- Amended provisions treating subsidy or grant as income u/s 2(24)(xvii) are prospective in nature and not applicable to assessment year prior to AY.2016-17) [ S.2(24)(xvii),28 (i),115JB ]

S.260A: Appeal –High Court – Penalty -Stay the proceedings to give effect to the order of Tribunal was rejected – Determination of the tax payable by the assessee is in the nature of money decree and hence should be paid to successful party – If assessee finally succeeds in appeal it would get the amount refunded with interest.[ S.271D ]

S. 271(1)(c) : Penalty – Concealment – Penalty imposed on addition made on the basis of confessional statement of assessee and supplier after search was held to be valid.

S. 263 : Commissioner – Revision of orders prejudicial to revenue –Order passed after expiry of two years from the end of the financial year was held to be bad in law . [S.260A ]

S. 254(2) : Appellate Tribunal – Rectification of mistake apparent from the record – Reliance on a decision not subject-matter of consideration during the hearing of appeal (and having influence on final view) constitutes mistake apparent from record.

S. 237 : Refunds – Revenue to ensure that unblocked amount is paid and credited to assessee’s account and interest on refund to be paid till the date of payment not up to date of unblocking.

S. 234E: Fee-Default in furnishing the statements – Demand under S. 200A for computation and intimation for payment of fees under S. 234E could not be made in the purported exercise of power under S. 200A prior to June 1, 2015 – Matter remanded.[S.200A]

S. 226 : Collection and recovery – Stay -Proceedings cannot be initiated before expiry of period of limitation to file before the Tribunal ie 60 days from the date of receipt of order- Revenue cannot issue notice for recovery directly to Assessee’s bank without giving an opportunity to be heard – Appropriate direction for re-crediting the amount to Assessee’s bank account issued to the Revenue.[S.220(6) , 253 ]

S. 220 : Collection and recovery – Assessee deemed in default –Maintainability of Writ vis-à-vis fraudulent withdrawal from attached bank account – Conduct of the assessee disentitles it to any relief under Art. 226 of the Constitution of India.