S. 56 : Income from other sources-Sale of immoveable property-Sale consideration and stamp value-Provisions is applicable to purchaser and not seller-Matter is remanded back to Assessing Officer.[S. 56(2)(x)]

S. 56 : Income from other sources-Purchase of land along with other co-owners-Difference between fair market value and purchase consideration was approximately 10 per cent of purchase consideration of property-Addition was deleted. [S.56(2)(x)]

S. 54 : Capital gains-Profit on sale of residential property-Co-owner-Deduction allowable proportionately to extent of investment [S. 45]

S. 50C : Capital gains-Full value of consideration-Stamp valuation-The AO adopted SRO rate as sale consideration-Not referred to DVO-Matter remanded to Assessing Office to refer determination of FMV of asset to DVO. [S. 45, 48]

S. 48 : Capital gains –Mode of Computation-Interest paid on loan-Clear another loan-Required to be reduced from sale consideration received by assessee, being one of components of cost of acquisition.[S. 45]

S. 9(1)(vi): Income deemed to accrue or arise in India – Aircraft leasing – Multilateral Instrument (MLI) – Principal Purpose Test (PPT) cannot be applied in absence of specific Sec. 90(1) notification – Lease rentals not taxable as royalty – No Permanent establishment in India- Entitle to treaty benefit – DTAA -India Ireland .[ S. 9(1)(i) , 90(1) , 143(3) 144C(13), 234A, 234B, 270A, Art . 5, 6, 7 , 8(1) , 12(3)(a) ]

S. 45(4) : Capital gains-Distribution of capital asset-Dissolution of firm-Depreciable assets-Block of assets-Transfer of depreciable capital assets-Incoming partner-Liable to capital gains tax under Section 45(4), even though there was no distribution of assets among partners upon dissolution-Section 50 does not apply when asset’s value has already been taxed as capital gains under Section 45(4) [S. 2(11), 45, 50, 50A]

S. 45 : Capital gains-Development agreement-Mere licence granted to developer without possession-No transfer-No capital gains.[S. 2(47)(v), Transfer of Property Act, 1882, S. 53A]

S. 45 : Capital gains-Business income-Sale of land-Part of property-No change in nature-Assessable as capital gains and not as business income. [S.28(i)]

S. 45 : Capital gains-Property sold by firm-Land was belong to one of the partner-Assessing Officer was required to arrive at figures of amounts realized on sale of assets owned by firm and compute profits on sale of same after deducting written down value as it stood in books of assessee-firm-No return was filed-Reassessment is affirmed. S. 147,148]