S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Offshore supply of equipments-Transferred outside India and entire sale was executed outside India-Revenue received therefrom was not to be taxed in India-Basic engineering design services were intrinsically in respect of setting up of Butane-1 plant and same were rendered through project office of assessee in India, consideration received in respect of said basic engineering design services was liable to tax in India as business income of PE of assessee-DTAA-India-France. [Art. 7(1), 12]

S. 2(22)(e) : Deemed dividend-Loans and advance-Provision is applicable-Matter remanded to Tribunal to decide on merit. [S. 260A]

Direct Tax Vivad Se Vishwas Act, 2020 .
S. 4 : Filing of declaration and particulars to be furnished – Tribunal recalled its order , restored appeal and posted it for fresh hearing- Doctrine of relation back were to be applied- Pendency of appeal of revenue before Appellate Tribunal- Rejection of application is held to be not valid [ Art , 226 ]
Direct Tax Vivad Se Vishwas Act, 2020 .
S. 4 : Filing of declaration and particulars to be furnished – Tribunal recalled its order , restored appeal and posted it for fresh hearing- Doctrine of relation back were to be applied- Pendency of appeal of revenue before Appellate Tribunal- Rejection of application is held to be not valid [ Art , 226 ]

The Direct Tax Vivad Se Vishwas Act, 2020.

S. 4 : Filing of declaration and particulars to be furnished – Appeal with drawn as dismissed .[ S.54B , 260A ]

S. 271AAB : Penalty-Search initiated on or after 1st day of July 2012-undisclosed income-Filed income tax return as per specified date-Penalty leviable only 10 %-Anonymous donations-derived income-purpose for which it is utilized-No need to mention address of donors. [S. 115BBC]

S. 271(1)(c) : Penalty-Concealment-Notice-Not specifying the charge-Quantum appeal admitted before High Court-Penalty was deleted. [S. 274]

S. 271(1)(c) : Penalty-Concealment-Failure to strike off the irrelevant default in show cause notice-Levy of penalty is held to be not valid. [S. 274(1)]

S. 271(1)(c) : Penalty-Concealment-Notice-Irrelevant words were not strike down by AO-Non application of mind by AO-Notice was bad in law-Levy of penalty is held to be bad in law. [S. 274]

S. 271(1)(c) : Penalty-Concealment-disallowance u/s.10A-only on presumption basis-Not due to inaccurate information-Penalty was deleted. [S.10A]

S. 271(1)(c) : Penalty-Concealment-Assessee’s good faith cannot be disproved-Transaction is held to be at ALP-Levy of penalty is held to be not justified. [S. 92CA(3)]