S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Operation of ships in international traffic-Shipping, Inland waterways transport-Freight income from shipping operation with India-Not taxable in India-DTAA-India-Singapore [S. 172(3), 172 (4), Art. 8, 24(1)]

S. 6(1) : Residence in India-Individual-Tie-breaker-Revised return-Shifted to Singapore with his wife and daughters for employment and resided in Singapore and had habitual abode therein only-Treated as resident of Singapore-Addition is deleted-Revised return is directed to be accepted-DTAA-India-Singapore [Art. 4]

S. 6(1) : Residence in India-Individual-Taxed on source basis-The Assessing Officer held that the assessee did not get himself entitled to status of a resident of USA automatically on his going to USA-Income is held to be taxable in India-Tie breaker test failed-Directed to grant foreign tax credit-DTAA-India-USA [Art. 4]

S. 4 : Charge of income-tax-Association of person-Purchase of property-Allotment letters issued to members-Members are real owners-Liable to be taxed in the hands of members and not in the hands of AOP. [S. 2(31)(v)]

Black Money (Undisclosed Foreign Income and Assets ) and Imposition of Tax Act, 2015
S. 43 : Penalty – Show cause notice – Since matter was at stage of show-cause notice, directed the statutory authority to adjudicate impugned show-cause notice having regard to response submitted by assessee and also specifically deal with issue relating to jurisdiction. [S. 131 (IA), Art . 226 ]

S. 276B : Offences and prosecutions-Failure to pay to the credit tax deducted at source-Pendency of proceedings before BIFR-Reasonable cause-TDS deposited before issue of notice-Criminal proceedings are quashed.[S.278AA]

S. 271(1)(c) : Penalty-Concealment-Furnishing Of Inaccurate Particulars-Notice not specifying the charge-Failure to specify the charge-Order of Tribunal deleting the penalty is affirmed.[S. 260A, 274, 275(1)(a)]

S. 268A : Appeal-Instructions-Circulars-Monetary limits-Bad debt-Lease and finance-SLP filed by revenue against said impugned order was to be dismissed as, in terms of CBDT Circular No. 17/2019 dated 8-8-2019, tax amount on which notice had been issued, was less than Rs. 2 crores.[S. 36(1)(vii)]

S. 254(1) : Appellate Tribunal-Powers-De novo enquiry-Bad debt-Where Appellate Authority remands case for a determination on a selected issue or aspect of assessment, parties are fully aware of parameters within which fresh enquiry is circumscribed and limited-Rigours of limitation are totally removed-Tribunal had directed Assessing Officer to consider question of disallowance for bad debts/advances being written off-Tribunal’s order did not set aside or cancel subject assessment orders requiring a fresh assessment. [S. S. 36(1)(vii), 153(5), 153(6), Art. 226]

S. 234B : Interest-Advance tax-Non-Resident-Entire tax was deductible at source-Not permissible to charge interest-Review petition is dismissed.. [S. 9(1)(1)]