S. 10B : Export oriented undertakings-Production and Export of pasteurized crab meat-procurement of non-living dead crab and then process into chemical mixed pasteurized crab meat in a series of manufacturing process-Fall under the new definition of manufacture-Deduction allowable. [S. 2(29BA)]

S. 10A : Free trade zone-Export turnover-Foreign currency-Export proceeds within six months-General permission to realise export proceeds within 12 months of export-Matter remanded.

S. 10(23C) : Educational institution-Surplus re deployed regularly for educational purposes-Lese rent paid to trustees neither excessive nor un reasonable-Denial of exemption. Was not justified [S. 10(23C)(vi), 13(1)(c)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-If an Indian agent has been paid an arm’s length remuneration, nothing further could be taxed in hands of Assessee-DTAA-India-Mauritius [Art, 5(4)]

S. 2(1A) : Agricultural income-Income derived from sale of saplings and seedling grown in a nursery alone shall deemed to be agricultural income-subsequent operation, i.e., supply of fertilizer, supply of soil, engaging horticulturists, insuring the plant, making pits and other related activities carried out in assessee’s nursery but in client’s site cannot be termed as secondary operation and hence not agricultural income. [S. 10(1)]

S. 271(1)(c) : Penalty-Concealment-Not specifying the charge-Levy of penalty is held to be not valid-Legal issue-Additional ground was admitted-Penalty provision u/s 271AAA is not applicable to search cases conducted after 1-7-2012. [S. 132, 254(1), 271AAA, 271AAB, 274]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Housing projects-Principle of consistency applied to an order under section 263 of the Act as well-Revision was barred by limitation-Issue was not subject of reassessment proceedings-Assessing Officer adopting permissible view-Revision is held to be invalid. [S. 80IB(10), 263(2)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Issue subject matter of appeal-Commissioner is not barred from exercising power of revision-Interest free funds-Direction was modified-Failure to deduct ta at source-Production expenses-Revision was held to be valid. [S. 36(1)(iii), 40(a)(ia), 263, Expln. 1(c)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revision of reassessment order-Reassessment was farmed without issue of mandatory notice under section 143(2) of the Act-Not curable defects-Revision assessment order which was non est in law is null and void. [S. 143(2), 143(3), 147, 148, 292BB]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Long term capital loss-Audit objection-Assessing Officer depending his view in response to audit query-Revision order is held to be not valid. [S. 143(3)]