S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Intermediary services-No technology made available-Not fees for technical services-Not taxable in India-Sale of equipment and payments carried outside India-Income attributable to Permanent Establishment is not taxable-DTAA-India-Sweden. [S. 9(1)(i), Art. 12]

S. 4 : Charge of income-tax-Foreign currency-Convertible bonds-Buy back of foreign currency bonds at discounted price-Foreign currency convertible bond proceeds were utilized for setting up a new manufacturing facility or expansion of manufacturing facility-Discount is capital receipt. [S. 28(i)]

S. 2(22)(e) : Deemed dividend-Not shareholder of company which had advanced loan to assessee-Loan cannot be treated as deemed dividend.

S. 40 (a)(iib) :Amounts not deductible- Fee- Tax – Gallonge fee , licence fee and shop rental (KIST ) with respect to EL-9 and E.L -I licence granted will fall with in the purview of section and hence disallowable -Surcharge on Sales tax and turnover tax is not fee or charge hence not disallowable – Interpretation of taxing statutes – Same statute using different terms and expressions – Must be taken to refer to distinct and different things . [ S. 37(1)), Kerala Abkari Act, 1077 (M.E.) S. 18 , Kerala Foreign Liquor Rules , 1953 , R. 15A ]

S. 271D : Penalty-Takes or accepts any loan or deposit-Whatsapp messages-Employee and promoter of group-Receipt of cash not proved-Penalty cannot be levied. [S. 269SS]

S. 271(1)(c) : Penalty for furnishing inaccurate particulars of income-Assessee intimated Assessing Officer well in advance of inadvertence of including receipt-Assessing Officer did not specify in notice whether notice is issued for concealing income or furnishing inaccurate particulars. [S. 143(2)]

S. 271(1)(c) : Penalty-Concealment-Disclosing full facts-Levy of penalty is held to be not justified. [S. 54F]

S. 263 : Revision of orders prejudicial to Revenue-Twin conditions to be satisfied-Assessment order cannot be said to be erroneous in law-Revision was quashed. [S. 54F]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny-The Revisional jurisdiction u/s 263 cannot be exercised for broadening the scope of jurisdiction that was originally vested with the A.O for limited scrutiny while framing the assessment and enlarging his scope of limited enquiry. [S. 143(3), 147]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Depreciation-Lease hold rights-Revision is held to be valid. [S. 32(1)(ii)]