S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for included services- Reviewing risk factor in particular project- Cannot be deemed to accrue or arise in India- DTAA-India-USA.[S.9(1)(vii), art.12]
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for included services- Reviewing risk factor in particular project- Cannot be deemed to accrue or arise in India- DTAA-India-USA.[S.9(1)(vii), art.12]
S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Computer software- Sale of conditional access systems and middleware products to Indian customers- Not taxable as royalty-SLP dismissed-DTAA-India-Switzerland.[art 12(3)]
S. 4 : Charge of income-tax-Sales tax incentive-Capital receipt-Not chargeable to tax. [S. 260A]
Prohibition of Benami Property Transactions Act, 1988 , Benami Transactions (Prohibition) Amendment Act, 2016 .
S. 2(9) : Benami Transactions- Provisional attachment order – Alternative remedy – Writ petition is dismissed .[ S.24(1), 24(3) , Art. 226 ]
Direct Tax Vivad Se Vishwas Act , 2020.
S. 4 : Filing of declaration -Delay in filing of appeal – Rejection of application by Designated Authority is affirmed .[ IT Act , 271AAB , Art. 226 ]
Direct Tax Vivad se Vishwas Act, 2020 Direct Tax Vivad se Vishwas Act, 2020
S. 3: Declaration- Rejection of declaration — Erroneous determination of tax — Part payment made is not considered – Disabled to file revised Form 3 due to technical glitches on Website – Marginal delay in filing Form 4 attributable to respondents — Department is directed to accept declaration subject to making of payments of tax. [ S. 3, 5(1),5(2) , Art. 226 ]
S. 80IB(10) : Housing projects- Area off residential units should not exceed specified limit — Entitled to deduction — SLP of Revenue is dismissed .[ Art. 136 ]
S. 276C : Offences and prosecutions-Wilful attempt to evade tax-
Penalty deleted-No concealment of income-Prosecution could not continue.[S. 277]
S. 264 :Commissioner-Revision of other orders-Claim to deduction under Section 80IA not made in return of income and assessment order passed-Principal Commissioner or Commissioner Competent to consider claim for deduction-Matter Remanded. [S. 80IA, 139, 263, Art.226]
S. 226 : Collection and recovery-Modes of recovery-Stay of recovery proceedings-Pendency of appeal before CIT(A)-Directed to deposit Rs 10 lakhs. [Art. 226]