S. 10(10AA) : Leave salary-Employee of the Central Government or State Government-Originally employed by Government but retiring from service of Government undertaking-Whether Entitled To Full Exemption — Matter remanded to Assessing Officer-CIT(A) has the power to entertain fresh claim which is not made in the return.[S. 143(1), 250]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Not adding any value to laboratory report but acting as medium to procure report from laboratory having higher credibility — Not fees for technical services.

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Income from software sales and support services — Addition is deleted-DTAA-India-Singapore.[art. 12(4)]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Permanent Establishment —Attribution of profit is without any basis.

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Dependent agency permanent establishment — Remunerated by the assessee for commission activities on arm’s length basis, no further attribution was required. The Assessing Officer was directed to delete the addition.

S. 4 : Charge of income-tax-Block of assets-Assessee reducing Block of assets from item and claimed depreciation on reduced Block of asset — Addition is not sustainable.[S. 2(11)]

S. 4 : Charge of income-tax-Interest received on deposits in Consolidated fund of India-Not chargeable to tax-Directed the Assessing Officer to verify the facts.[S.143(3)]

S. 4 : Charge of income-tax-Principle of mutuality — Payments were reimbursement and exempt from taxation and covered by principle of mutuality.

S. 4 : Charge of income-tax-Capital or revenue-Duty credit entitlement under served from India Scheme-credit only be utilised by set off against duties arising on purchase of capital goods or spare-Capital in nature.[S. 28(i), 32, 43(1)]

S. 2(22)(d) : Dividend-Any distribution to its share holders on the reduction of its share capital-Buy back of shares-Scheme of arrangement or compromise-There was a capital reduction and distribution out of accumulated profit of company to its shareholders, same would entail release of all or part of assets of a company on reduction of capital and would attract provisions of section 2(22)(d), and consequently, assessee was liable for payment of DDT under section 115-O. [S. 115O, 115QA, Companies Act 1956, S. 77, 77A 100 to104, 391, 292, 393]