S. 9(1)(vi): Income deemed to accrue or arise in India]-Royalty-license fee for granting broadcasting right-Not royalty]-Apportionment of license fee-‘live coverage’ of the event has very large viewership as compared to a recorded broadcast and, therefore, it is appropriate to allocate 10 per cent of the license fee for broadcasting rights towards recorded events and 90 per cent towards ‘live coverage-DTAA-India]-USA.[S.90, Art. 12(3)]

S. 4: Charge of income-tax -Accrual-Interest receivable from foreign subsidiaries-Financial year-Failed to reconcile- Addition is affirmed.[S. 5, 145]

S. 2(22)(e) : Deemed dividend-Loan received from third parties not related to the company in which the assessee had a substantial interest- Difficult to presume that there was an arrangement or colourable device in respect of the transactions-loans received by the assessee from Sunil Jain and Heera Lal Modi cannot be treated as deemed dividend.

Black Money (Undisclosed Foreign Income and Assets) and Imposition Act, 2015.

S. 10: Assessment-Undisclosed asset located outside India-Bank account outside India-Documents were given to the bank much before the enactment of Black Money Act-Inheritance-Income earned abroad-Addition was deleted. [S. 10(3)]

S. 271(1)(c): Penalty-Concealment-Addition on account of notional rental income-Rental income-Arithmetical error-There was a shortfall in disclosing rental income-Voluntary disclosure of income to cover any omission-No concealment penalty-Appeal admitted by High Court-No penalty-Penalty order barred by limitation. [S. 245(2C), 245 D(4), 275(1)(c)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Lack of proper enquiry-Credit for tax deducted at source-No double grant of TDS credit-Revision order was set aside. [S. 142(1), 143(2),148]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Lack of proper enquiry-Long-term capital gains-PCIT has failed to establish the erroneous character of the assessment order and that too in such a manner that it is prejudicial to the interest of the Revenue-Revision order is quashed and set aside. [S. 45, 143(3)]

S. 263: Commissioner-Revision of orders prejudicial to revenue-
Assessment order passed pursuant to invalid satisfaction note-PCIT was not empowered to revise the assessment orders by relying on seized documents in respect of which the AO did not record any satisfaction in the satisfaction note-The assessment orders are ab initio void-Invalid orders cannot be subjected to revision-The order passed by the Principal CIT is not sustainable-The revision order was quashed and set aside. [S. 153C]

S. 263: Commissioner-Revision of orders prejudicial to revenue-Capital gains-Cost of acquisition-Based on FMV as on 1st April, 2001-Revision order is not valid. [S. 48, 49,55(1)(b)]

S. 254(1): Appellate Tribunal-Powers-Opportunity of being heard-failure to decide on merits-Order of CIT(A) was set aside, and Notices sent to wrong e-mail IDs-The issue is restored to the AO to decide in accordance with law. [S. 69A, 251]