S.14A : Disallowance of expenditure-Exempt income-Interest free funds-Not recorded dissatisfaction-Addition is deleted. [R.8D]

S. 10B: Export oriented undertakings-Non-realisation of export proceeds within six months-CIT(A) has rightly issued directions to allow the assessee’s claim in the year of return after due verification of the facts of return of goods-Provisions for doubtful debts and advances-Not to be added to book profit.[S.115JB]

S. 10A : Free trade zone-Export turnover-Total sales-Deemed exports-Export turnover should constitute at least 75 per cent of the total turnover, although in quantitative terms, the export quantity might be less than 75 per cent of the total sale quantity.[S.10A(2)(ia), Export-Import Policy 1992-97]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Global online learning platform-The receipts of the assessee do not qualify as fees for included services under art. 12(4) of India-USA tax treaty-DTAA-India-USA. [S. 144C(13), Art. 12(4)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Functions as selling and purchasing agent-Because the nature of business of trading is a continuous flow of the business process, that cannot be a foundation to conclude a principal-agent relationship for the purpose of art. 5 of the DTAA-There is no PE of assessee in the form of ITPL-DTAA-India-Japan. [S. 90, Art. 5(6)]

S. 271(1)(c) : Penalty-Concealment-Disallowance of excess brought forward losses pursuant to MAP order-Revised computation filed-Time for filing revised return has expired-Paid additional tax along with interest-Penalty is deleted. [S. 143(2), 139(1), 139(5)]

S. 271(1)(c) : Penalty-Concealment-Bogus purchase-Addition made on estimate basis-Penalty is not leviable-Omission to strike off one of the twin charges in the notice-Not invalidate penalty proceedings. [S.69C, 274]

S. 270A:Penalty for under-reporting and misreporting of income-Omission to file return-Sale of property TDS deducted-Penalty is deleted. [S. 139,194IA Form No 26AS]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Non-Resident-Trading in shares-CIT has not pointed out any reason for doubting the explanation-Revision order is set aside.[S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Dividend-Mutual fund and Equity shares-Explanation 2 is not applicable-Revision is quashed. [S. 10(35), 115BBDA 143(3)]