S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Global online learning platform-The receipts of the assessee do not qualify as fees for included services under art. 12(4) of India-USA tax treaty-DTAA-India-USA. [S. 144C(13), Art. 12(4)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Functions as selling and purchasing agent-Because the nature of business of trading is a continuous flow of the business process, that cannot be a foundation to conclude a principal-agent relationship for the purpose of art. 5 of the DTAA-There is no PE of assessee in the form of ITPL-DTAA-India-Japan. [S. 90, Art. 5(6)]

S. 271(1)(c) : Penalty-Concealment-Disallowance of excess brought forward losses pursuant to MAP order-Revised computation filed-Time for filing revised return has expired-Paid additional tax along with interest-Penalty is deleted. [S. 143(2), 139(1), 139(5)]

S. 271(1)(c) : Penalty-Concealment-Bogus purchase-Addition made on estimate basis-Penalty is not leviable-Omission to strike off one of the twin charges in the notice-Not invalidate penalty proceedings. [S.69C, 274]

S. 270A:Penalty for under-reporting and misreporting of income-Omission to file return-Sale of property TDS deducted-Penalty is deleted. [S. 139,194IA Form No 26AS]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Non-Resident-Trading in shares-CIT has not pointed out any reason for doubting the explanation-Revision order is set aside.[S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Dividend-Mutual fund and Equity shares-Explanation 2 is not applicable-Revision is quashed. [S. 10(35), 115BBDA 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Unsigned assessment and non-service of order-Physical copy was signed-Up loaded unsigned copy-Revision is valid.[S. 143(3), 153C]

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Territorial jurisdiction of CIT(A)-Appeal filed before non-jurisdictional CIT(A)-Order by the CIT(A) CIT(A), Noida is set aside and the matter is remanded to the CIT(A), Ghaziabad to adjudicate the appeal afresh in accordance with law. [S. 246A]

S. 199 : Deduction at source-Credit for tax deducted-Salary-Matter remanded to the file of CIT(A) for verification. [S. 192, Form no 26AS]