S. 23 : Income from house property-Annual value-Unsold flat as stock in trade-buildings or land appurtenant thereto-Occupied by owners for the purpose of business-Excluded for the purpose of computing notional rent. [S. 22]

S. 14A : Disallowance of expenditure-Exempt income-Disallowance is restricted to extent of exempt income. [R.8D]

S. 12A : Charitable or religious trust-Registration-Cancellation of registration-Assessee unwilling to avail benefit of registration obtained u/s. 12A cannot be bound to, by action of or by inaction of revenue authorities, continue with said registration-Benefit could not be forced upon the assesseee. [S. 12A(3), 13(1)(d)]

S. 11 : Property held for charitable purposes-Rental income derived from letting out studio to artists for teaching Indian classical music comes within the ambit of “education”-Assessee is entitled to exemption. [S. 2(15), 11(4A)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Income from sale of software license-Not assessable as royalty-DTAA-DTAA-India-USA. [Art. 5, 7, 12]

S. 9(1)(i) : Income-Deemed to accrue or arise in India-Shipping, Inland waterways transport-Wholly managed or controlled from the UAE-satisfied requirement of article 4-Entitled to treaty benefit-DTAA-India-UAE. [S. 90, 144C, Art. 4(1)(b), 8(1), 29]

S. 148: Reassessment – Notice-Constitutional validity – The delegation authorized being only for the purpose of enlarging limitation under a valid law, such delegation could not be exercised to resurrect the provision of law that stood omitted from the statute book by virtue of its substitution made by the Finance Act, 2021, w.e.f. 01.04.2021 – Reassessment notices issued under section 148 of the Act are quashed-It is left open to the assessing authority to initiate – re-assessment proceedings in accordance with the provisions of the Act, as amended by the Finance Act, 2021 after making due compliance as required under the law. [S. 147, 148A, 149, 151, 151A, 153, 292 Relaxation of Certain Provisions) Act, 2020 (TOLA), S. 3(1) of the Act 38 of 2020, Art. 226]

S. 292B : Notice not to be invalid on certain grounds – Notice issued in the name of a dead person is a nullity. [ S.153C ]

S. 245C : Settlement Commission – Settlement of cases – Conditions – Subsequent additional statements could not be relied upon in order to satisfy requirements of S/245C and ITSC has exceeded its jurisdiction in setting aside such issue as regular assessment has to be made in such case. [ Art . 226 ]

S. 90: Double taxation relief – Assessee – Company being a tax resident of Singapore is eligible to the benefits of India-Singapore tax treaty with respect to sale of shares in Indian subsidiary – LOB clause is not applicable as such sale was pursuant to genuine business restructuring and MNC’s activity of being an investment holding company is a bonafide business activity – Hence, no capital gains on sale of shares of Indian subsidiary by a Singapore holding investment company.