S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping business-Freight charges collected in India-Certificate from tax authorities that amount was assessable in Singapore-Earning not taxable in India-DTAA-India-Singapore-(1994) 209 ITR (St.) 1) [S.44B, Art. 24]

S.50: Benami transactions-Offences and prosecution-Demonetisation-Jurisdiction of court-Complaint filed before Special Court under Benami Prohibition of Benami Property Transactions Act Cognizance of offence by trial court Valid Act, 1988. [S. 53, Criminal Procedure Code, 1973, S. 200, 482]

S. 2(1)(a)(ii): Application-Pendency of appeal-Maintainability-Certified order given on 10-7-2020-Application dated 2-5-2020 maintainable-Directed to entertain the application. [Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Death of assessee-Department not informed of death of assessee-Legal heir deemed to be assessee-Directed to respond to notice under section 142(1)-Assessing Officer directed to issue subsequent notices in name of legal heir.[S. 142(1), 148A(b), 148A(d), Art. 226]

S. 10 (23C): Educational institution-Hospital or medical institution Grand-in-aid from Government Effect of section 10(23C) (iiiac)-Interest on grants-in-aid-To be added to grants-in-aid or returned to Government-Interest entitled to exemption [S. 10(23C) (iiiac).]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Tribunal holding transfer pricing to be proportionate to value of international transaction-Business expenditure-Provision for warranty-Tribunal deleting disallowance Proper-No substantial question of law. [S.37(1), 260A]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-UOI v. Ashish Agarwal (2022) 444 ITR 1 (SC) Notice under section 148 deemed to be issued under section 148A-Assessee has right to reply to notice.[S. 148, 148A(b) 148A(d), Art.226]

S. 4 : Charge of income-tax-Principles of mutual association-Matter remanded. [S. 260A]

S. 44BB : Mineral oils-Computation-Presumptive tax-Non resident-Taxability in India-Undertaken for 119 days-Less than 183 days-No permanent establishment in India-Not taxable in India-DTAA-India-Singapore [Art. 51, Art.226.]

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts or new tangible material available-Payments under settlement with on-site employees in class action law suit in United States of America-Reassessment to disallow deduction on ground that amount expended was penalty-Payment not in nature of penalty-Reassessment not sustainable.[S. 37(1), 148, Art. 226]