S. 9(1)(vi) : Income deemed to accrue or arise in India-Vessel hire charges-Royalty-Fees for technical services-Charter contract for transporting coal from one port to another through its ship-Not royalty-Rightly offered to tax under section 44B of the Act-DTAA-India-UAE [S. 9(1)(vii) 44B, Art. 13]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Permitting right to use of brand name/trademark-Taxable as royalties-DTAA-India-Turkey. [S. 2(47)Art. 12(3), 13(6)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Computer software-Royalty-Income from sale of software to its distributor in India-Not in the nature of royalty-Not taxable in India-DTAA-India-Ireland.[S. 9(1)(vii), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of computer software products-Not royalty-DTAA-India-USA [Art. 12(3)]

S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Interest paid by Indian Branch of assessee-Japanese bank to its overseas head office was not chargeable to tax in India-DTAA-India-Japan [Art. 11]

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 ]