S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty- Deduction of tax at source-Payments to Non-Residents-Telecommunications operators for providing inter-connectivity services and transfer of capacity in foreign countries-Not chargeable to tax as royalty-SLP of Revenue is dismissed. [S. 195, 201, Art. 136]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Deduction of tax at source-Payment to Non-Resident-Royalty User licence agreement for use of computer software by Non-Resident supplier to distributor and resold to resident end-user, or directly supplied to resident end-user-Not royalty for use of Copyright in computer software-Not liable to deduct tax at source-Review petition is dismissed on account of delay of 515 days and also on the merits. [S. 195, Copyright Act, 1957, S. 14(a), 14(b), 30]

S. 4 : Charge of income-tax-Accrual-Banks-Interest on bad and doubtful debts is not taxable.[S. 5, 119, Art. 136]

S. 4 : Charge of income-tax-Accrual-Interest on sticky advances credited to memorandum account is not taxable. [S. 145, Art. 136]

S. 147: Reassessment – Limitation – TOLA did not apply as the limitation period expired before 20.03.2020- Notice under section 148 issued in 31-7-2022, which is beyond the prescribed time limit – Reassessment held to be invalid. [S. 68, 133(6), 142(1), 148, 148A(b), 148A(d), 149, 151, 154, 115JB]

S. 147: Reassessment – With in four years- Change of opinion – Alleged double deduction – No failure to disclose material facts – Reassessment is quashed and set aside. [S. 143(3), 148, 149, 151, 36(1)(vii), 37(1), Art. 226]

S. 147: Reassessment – Revision -Notional rent – Income from house property – Change of opinion – Reopening based on issues already examined in revision proceedings – The original assessment order dt.31.12.2015) is no longer existed, as it was set aside under Section 263- Making the reopening procedurally invalid – Reassessment is quashed . [S. 22, 143(3), 148, 149, 151, 263, Art. 226]

S. 132: Search and Seizure – Ultra vires seizure – Stock in trade – Writ petition disposed of with directions to avail alternative remedy under S. 132B of the Act . [S. 131(1A), 132(1)(iii), 132B, Art. 226]

S. 271(1)(c) : Penalty-Concealment-Deemed addition- Addition under section 56(2)(vii)(b)- Penalty is deleted. [S. 56(2)(vii)(b)]

S. 270A : Penalty for under -reporting and misreporting of income – Not specifying the limb – Levy of penalty is not valid . [ S.270A(8) 270A(9) ]