S. 10A : Free trade zone-Set-off losses of STP/SEZ unit against income of non-STP units-Allowed to be set off-Export turnover-Deemed export, reimbursement of expenses, expenses incurred in foreign currency, delayed export proceeds and VAT/GST would form part of export turnover-Corporate office expenses-Allowed on ad hoc percentage of 20 percent and not based on turnover of various undertakings for purpose of deductions under section 10A.[S. 80IB, 80IC]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Providing access to computer software to Indian comoany-Not royalty-Not liable to be taxed in India-DTAA-India-UK. [Art. 13, Copy right Act, 1957, S. 14, Art. 226]

S. 4 : Charge of income-tax-Interest-Interest accrued had to be utilized only for purpose of scheme-Not assessable as revenue receipt.

S. 250 : Appeal-Commissioner (Appeals ) -Procedure -Faceless Appeal Scheme – Video Conference -Natural justice – Opportunity for personal hearing not granted – Retrospective effect- Order set aside and remanded back. [ S. 250(6B) , National Faceless Appeals Scheme 2020, Rule 12(2), 12(3), 13(2) ]

S. 9(1)(i): Income deemed to accrue or arise in India – Permanent establishment – Interest will not be taxed at a higher rate- DTAA- India- Japan . [ Art, 7, 11(2)(11(6), 14 ]

S. 90: Double taxation relief – Foreign Company – discrimination allowed – Company has not made prescribed arrangement-DTAA-India -Korea . [ S. 2(22A), Art, 25(1)]

S. 144C: Reference to dispute resolution panel – Rectification application by TPO – Rectification order by DRP – Not maintainable. [ S. 144C(14), 154 ]

S. 260A : Appeal – High Court -Delay in disposal of appeals – Change in Panel counsels – CIT(judicial) to make necessary arrangements in two weeks.

S. 10(1) : Assessment-Notice under section 10(1) jurisdictionally defective and violative of the principles of natural justice on account of simultaneous proceedings under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 and Income-Tax Act, 1961-Order was quashed. [S. 2(11). 4(3), 14, 59].

S. 17 : Wealth tax escaping assessment-Non-supply of reasons-Off-shore irrevocable discretionary trusts-Reassessment proceedings null and void owing to non-supply to the assessee of the reasons recorded-Off shore trust assets including immovable property in Singapore and London were not vested in the assessee and such assets held through offshore corporate vehicles are exigible only in the hands of such vehicles and not in the hands of the assessee-Deposits in offshore banks do not constitute an asset and hence are excluded from chargeability to tax under Wealth-tax Act-ITSC commission order is not binding on wealth tax proceedings. [S. 2(ea), 2(m)]