S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Provision of connectivity solutions-Services to customers of Indian companies outside India-Consideration received on basis of agreements from telecommunication operators for Bandwidth and inter-connectivity usage of their customers-Provisions of double taxation avoidance agreement override statutory provisions and amendments thereto-Receipts not assessable as royalty in India-No alienation of copyrighted articles, patents, trademarks, designs, models, secret formulae or processes, property or information-Mere advantage or benefit derived from service provided cannot be countenanced to fall within meaning of expressions use or right to use-Receipts under agreements for provision of bandwidth not royalty-Use or right to use-DTAA-India-Singapore.[S.90(2),260A, Art.3(2), 12(3)]

S. 250 : Appeal – Commissioner (Appeals) – Non-speaking order – Procedure Cash credits – Un secured loan from Magunta exports – Return showing nil income –Duty of CIT(A) – Duty to give reasons for order – Conclusions were in the nature of ipse dixit and no supporting reasons were discernible – Order of CIT(A) confirming the addition is set aside – Matter remanded to the file of the CIT(A). [ S. 68, 115BBE, 250, Art .226 ]

S. 271G : Penalty-Documents-International transaction-Transfer pricing-TPO had not proposed any adjustment-Levy of penalty is not justified. [S.92C, 92D]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Winnings from lotteries or crossword puzzles-Online gaming-Winning amount paid to players of games available on its website-Revision is justified for for limited purpose of examining issue of deduction of TDS under section 194B.[S. 194B]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains-Urban agricultural land-Capital asset-Liable to be assessed as capital gains-Revision is affirmed. [S. 2(14), 45]

S. 263 : Commissioner-Revision of orders prejudicial to revenue–Exemption-Investment in residential house-Time limit-Date of transfer of shares-Capital gains-Investment in a residential house-Investment made in land beyond period of two years-Revision is not justified-Entitle to exemption.[S. 45, 54F]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Dealer in gold-Loss through MCX transactions for hedging its stock-in-trade-Loss is business loss-Not speculative-Revision is not valid.[S. 28(i)) 43(5)(d), 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Income from other sources-Share premium-Discounted Cash flow (DCF) method-Selected for scrutiny on the ground that large share premium received during relevant assessment year-Assessing Officer accepted the claim-Commissioner was not justified in setting aside order of AO under section 263 on ground that AO had merely accepted claim of share premium without making enquiry with respect to valuation of shares. [S. 36(1)(va), 56(2)(viib),142(1), R.11UA]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Examined all details-Possible view-Revision is not valid.[S. 10(21)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Donation to political parties-No enquiry was made by the Assessing Officer-Revision is held to be justified.[S.80GGC]