S. 14A : Disallowance of expenditure-Exempt income-No satisfaction is recorded-Disallowance not sustainable. [ R.8D ]

S. 12AB: Procedure for fresh registration-Remanded to Commissioner (E) to allow assessee to file requisite details of activities undertaken including audited accounts for financial years 2020-21 and 2021-22 and decide application a fresh.

S. 10B: Export oriented undertakings-Senior management salaries had been allocated in ratio of turnover of export-oriented units and other units.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Residuary article-Reimbursement of software licence fees-Absence of Permanent Establishment not taxable in India-DTAA-India-United States of America. [S.56 , 115A , art. 7, 12, 23(3) ]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-No material on record to demonstrate that assessee made available technical knowledge, skill, experience and know-h ow-Commissioner (Appeals) attributing 50 Per Cent. of receipts to consultancy services based on estimate and without any reasonable basis-Addition not sustainable-DTAA-India-UK [ art. 12(3)(b), 13(4) (c ) ]

S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Providing online technology learning platform on its website-Subscription fee is not consideration for use or right to use any industrial, commercial or scientific equipment-Subscription revenue received is not taxable as royalty–DTAA-India-USA [art. 12(3) ]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Non-Resident-Lease of Helicopter to Indian entity-Royalty income could not be added on notional basis-DTAA-India-United Arab Emirates. [Art. 12]

S. 9(1)(ii) : Income deemed to accrue or arise in India-Salaries-Employed with Company in India-Sent to China on assignment-Salary paid in India by employer-Salary earned for services in China is not taxable in India-DTAA-India-China. [S. 5(2), Art. 15(1) 23]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Non-Resident-Supply of software and automated services-Arm’s length-Attribution of profits-DTAA-India-Ireland . [ S.92C , art.5, 11 ]

S. 4: Charge of income-tax-Sales tax subsidy-Capital receipt-Depreciation-Actual cost-Sales tax subsidy is not to be reduced from block of assets. [ S. 2(11), 32 ]