S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Permanent Establishment — Providing online decision support applications for Airline companies in India-Not business income — Taxable only on gross basis under Section 115A at 10 Per Cent. — Expenses not allowable —DTAA -India -USA.[S. 9(1)(i), 44DA,

S. 4 : Charge of income-tax -Accrual -Service charges accrued but not received -Addition is not justified. [S. 5, 145]

S. 4 : Charge of income-tax-Diversion by overriding title -Transfer of interest receipts to tribal development fund (TDF) and watershed development fund (WDF) per scheme devised by Government of India for promotion of investments in agriculture and rural development- Not chargeable to tax. [S. 145]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Shares issued at premium-DCF method-Commissioner in Revision proceedings cannot direct the Assessing Officer to adopt the NAV method-TDS on interest income-Interest income om fixed deposit for obtaining the loan for obtaining the bank guarantee-Directly linked with activity of setting up hotel and is to be viewed as a capital receipt going to reduce cost of construction-Revision order is quashed.[S. 4, S.56(2)(viib), 199, R.11UA, R.37BA]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Educational institution-School-No fee is charged from students-Accumulated surplus for purpose of future application to set up school-Entitle to exemption-Revision is held to be not justified. [S. 10(23C)(iiiad), 12A, 12AA]

S. 144C : Reference to dispute resolution panel-Assessment-Limitation-No variation in returned income-Assessing Officer ought to have passed assessment order under section 143(3) of Act within limitation time prescribed under section 153(1), i.e., within 21 months from end of assessment year-Order is barred by limitation. [S. 143(3), 153(1)]

S. 68: Cash credits-Income from other sources-Agricultural income-Lease rent-Addition made in earlier year-Taxing the said income again is deleted.[S.56]

S. 56 : Income from other sources-Cumulative preference shares at premium-Produced valuation report for justifying the issue of shares at premium-Deletion of addition by CIT(A) is affirmed. [S. 56(2)(viib), R.11U, R.11UA]

S. 56 : Income from other sources-Interest on compensation-Enhanced compensation-Compulsory acquisition of agricultural land-Not taxable. [S. 56(2), 145A, Land Acquisition Act, 1894, S. 28]

S. 54 : Capital gains-Profit on sale of property used for residence-Invested a portion of capital gains-Sale of old property on 23-10-2018-Possession of new flat on 24-12-2018-Date of possession of flat would be actual date of purchase for claiming exemption under section 54-Entitle to exemption. [S. 45]