S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Presumptive taxation-Permanent Establishment-Fixed place of profession-Akin to a fixed place of business-No permanent establishment in India-presumptive tax is not applicable-Income is taxable at regular rate. [S.44DA-92F(iiia), 115A]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Receipts of fabrication charges for refurbishing of bushes-Not fees for technical services taxable in India-No permanent establishment in India-DTAA-India-Singapore [S.9(1(i), Art. 12]

S. 271A: Penalty – Failure to keep maintain -Retain books of accounts –Documents -Penalty order is set aside. [S.44AA]

S. 271(1)(c) : Penalty- Concealment – Deeming provision –Capital gains -Agreement value -Stamp valuation- Levy of penalty is not valid. [S.50C]

S.271(1)(c): Penalty -Concealment -Not striking off irrelevant portion in the notice – Penalty order is quashed. [S. 69C, 143(3)]

S. 263 : Commissioner -Revision of orders prejudicial to revenue- Document identification No (DIN)- Order is bad in law. [S. 153C]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Capital gains -Profit on sale of property used for residence -Capital gains not deposited in CGAS -Capital gain was invested in purchase/construction of residential house within time limit prescribed under section 54(1) –Revision is held to be not valid. [S. 45, 139(1)]

S. 263: Commissioner -Revision of orders prejudicial to revenue- Long term capital gains- [S. 45, 115O, 115P]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Revision on the basis of investigation/ enquiries conducted post completion of assessment -Sale of shares -Long term capital gains – Reassessment order is invalid. [S. 143(3)]

S. 251: Appeal -Commissioner (Appeals) -Powers- Co-terminus -Fresh claim of deduction- Allowed deduction. [S.80C]