S. 9(1)(vii): Income deemed to accrue or arise in India-Royalty/FTS-Foreign company-Taxability of (i) receipt from sale of designs and drawings and (ii) Offshore supply of plants and equipment-Reimbursement for SAP installation-No PE-Not taxable as FTS or royalty-DTAA-India-Germany.[Art. 12]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-AO taxed the services of the Assessee as FTS-Held, AO did not clarify what information was required from Assessee-Addition is deleted-DTAA-India-Singapore.[Art. 12(4)(b)]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Royalties-Consideration from licensing of software and support services-No permanent establishment-Non-taxable business income in the absence of any Permanent Establishment-Addition as FTS/FIS was deleted-DTAA-India-France.[S.9(1)(i), 9(1)(vi, 90, Art. 12]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Make available-IT support services to its Indian AE-Non support services-Amount received was not taxable as FTS-DTAA-India-UK [Art. 13]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Sale of software products to Indian distributors for onward resale to end-users-Product simpliciter facilitating digital security and not for rendering technical services, such income was not taxable in India as FTS-DTAA-India-Ireland [Art. 12 (3)(b)]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping, Inland waterways transport and air transport-International traffic-UK tax resident airline-Received delivery order charges in connection with transportation of passengers, mail, livestock and goods by air in international traffic-Considered directly connected with operation of aircraft under Article 8(3) of India-UK DTAA and thus, would not be taxable in India-DTAA-India-UK [Art. 8]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping, Inland waterways transport and air transport-International traffic-Operation of ships in international traffic-Multiple ports in India-Benefit of Article 8 of India-UAE DTAA was to be extended to entire freight receipts irrespective of whether earnings were relating to feeder vessels or by ships in international traffic-Profit derived from shipping business as envisaged under article 8 of India-UAE DTAA and was not taxable as business profit in India-DTAA-India-UAE [Art 8]

S. 4: Charge of income-tax-Capital or revenue-Compensation received for underperformance of wind turbine generators (WTGs)-Capital receipt. [S.28(i)]

S. 4: Charge of income-tax-Capital or revenue-Grants-Capital reserve account-Road project-Infrastructure development-Grants/contributions from State Government for completion of road projects undertaken by it on BOT basis-Grants/contributions were a capital contribution by State Government towards the cost of projects-Not taxable as revenue receipts. [S. 28(i), 145]

S. 2(22)(e): Deemed dividend-Refundable rental security deposit from tenant-Cannot be assessed as deemed dividend-Matter remanded.