S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Not dependent agent-No substantial transaction-Income is not chargeable to tax in India-Fees for technical services-Reimbursement of salaries of seconded employees-Tax deducted at source-issue is remitted to the AO for fresh adjudication as per law-DTAA-India-USA.[S.90, Art, 12(4)]

S. 5 : Scope of total income-Income-Accrual-Notional interest-Waiver of interest on Compulsorily Convertible Debentures-Interest waived before the end of financial year-Commercial expediency-No addition can be made on account of interest income on notional basis. [S. 4, 143(3) 145]

S. 13A:Political parties – Delay in filing return – Cash donations exceeding limit – Strict compliance required –Not entitle to exemption if the return is filed after due date – Exemption denied – Appeal dismissed . [S. 13A(d), 139(1), 139(4), 139(4B), 143(3), Representation of People Act, 1951, S. 29A]

S. 271(1)(c) : Penalty – Concealment – Information from sales-tax authorities – Bogus purchases – Hawala parties – Estimated additions – Quantum restricted to 12. 5% of bogus purchases – Penalty is leviable . [ S.69C ] S. 271(1)(c) : Penalty – Concealment – Information from sales-tax authorities – Bogus purchases – Hawala parties – Estimated additions – Quantum restricted to 12. 5% of bogus purchases – Penalty is leviable . [ S.69C ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Central Circle – Notice issued by jurisdictional Assessing Officer (JAO ) rather than the Faceless Assessment Officer (FAO)- Notice and consequential order under section 148A(d) is quashed and set aside – Liberty is granted to the Revenue to seek revival if the Supreme Court later reverses the decision in Hexaware Technologies Ltd . [ S. 148 , 148A(b), 148A(d) , 151A Art , 226 ]

S. 271(1)(c) : Penalty – Concealment – Notice must specify the charge – Notice must be precise and there should be no room for ambiguity – Veena Estate (P.) Ltd v. CIT [2024] 158 taxmann.com 341/ 461 ITR 483 (Bom)( HC) , distinguished- Order of Tribunal is affirmed .[ S. 260A ]

S. 2(22)(e): Deemed Dividend – Advance received from closely held company by its shareholder – Holding more than 10% -Commercial transaction – Not assessable as deemed dividend .

S. 271(1)(c) : Penalty-Concealment-Estimate of income-Estimation of rate of NP on gross receipts-Rejection of books of account-Penalty is deleted.[S. 145]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Reimbursement of expenditure on account of Employee Stock Option Plan (ESOP) costs incurred by holding company-Allowable as deduction-Revision order is quashed.[S. 37(1)]

S. 254(1) : Appellate Tribunal-Powers-Additional claim-Not made through revised return of income-Restrictions does not apply to appellate authorities. [S. 139]