S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Fees for included services-Conceptual design services-Make available-Designs, drawings, lay-outs etc. provided by assesse-Not assessable as fees for technical services-DTAA-India-USA [S.115A, art. 12(4)(b)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-Videos on database-Learning platform on its website-Subscription revenue-Subscription fees could not be said to be for imparting of any information concerning industrial, commercial or scientific experience-Not taxable as royalty-DTAA-India-USA. [S.9(1)(vii), art. 12(3)(a)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Payment of compensation to overseas cricket association-Premature termination of agreement-Payment is not chargeable to tax in the hands of South Africa Cricket Board-Cricket South Africa (CSA)-No obligation to deduct tax at source-No Permanent Establishment in India-DTAA-India-South Africa. [S. 5(2), 90, 115BBBA, 194E, 195 Art.5(5), 7]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Commission-Not chargeable to tax in India-Not liable to deduct tax at source-Royalties/Fees for technical services-Computer software-Not liable to deduct tax at source-OECD Model Convention-Art.12 [ S. 9(1)(vi), 9(1)(vii), 195]

S. 281 : Certain transfers to be void-Priority of debt-Secured creditor-Mortgage of land and construction-The omission of dates of proceedings and mortgage of property in order to demonstrate proceedings initiated before mortgage of property-Finding on date of initiation of proceeding prior to date of creation of mortgage not found in order-Order vague-Order set aside. [ITR. 83 Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002-Recovery of Debts and Bankruptcy Act, 1993, Art. 226]

S. 271(1)(c) : Penalty-Concealment-Furnishing inaccurate particulars of income- Subsidy-Capital or revenue-Debatable issue-Order of High Court deleting the penalty is affirmed-SLP of Revenue is dismissed. [Art. 136]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Set-off of loss-Derivative loss-Business income-Documents placed before tribunal not furnished before Principal Commissioner- Non-speaking order-Matter remanded to PCIT. [S.73(1), 254(1), 260A]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Revision-No finding that assessment order was prejudicial to revenue-Not given adequate opportunity to the assessee to be heard-Revision order is quashed-Revenue is directed to pay the cost of Rs.10000 which shall be deposited with Allahabad Legal Service committee. [Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains or business income-Investment in stock in trade-Deemed dividend-Capital contribution by company-Not loan or advance-Commercial transaction-Order of Tribunal quashing the revision is affirmed.[S. 2(22)(e), 28(i), 45]

S. 260A : Appeal-High Court-Delay in filing appeal of 3270 days-Time required to clear certain objections & some time was required to arrange certain documents-Appeal dismissed.[S.153A]