S. 9(1)(vi) : Income deemed to accrue or arise in India -Royalty -Taxation of receipts from the sale of software to Indian entities under the India- agreements merely granted the right to use software without transferring copyright ownership -Held, not liable to tax-DTAA -India – Singapore. [Art. 12(3)]

S. 6(1) : Residence in India -Individual -Employment outside India -Business or profession -Stayed 176 days during year -Entitled to claim the benefit of the extended period of 182 days as provided in explanation 1(a) to section 6(1) of the Act -Appeal of Revenue is dismissed. [S. 6(1)(a), 6(1)(c)]

S. 2(15) : Charitable purpose-General public utility-Publishing newspapers -Receipts more than 10 lakhs -Matter remanded for verification. [S. 11, 12A]

S. 254(1) : Appellate Tribunal-Powers Death of the assessee during pendency of appeal-Tribunal has the power to decide the appeal on the relevant material-Revenue has not brought on record the details of legal Representative for more than 18 months-Tribunal decided the appeal on merits. [S. 45, 254(1), ITAT R.1963, R.26]

S. 253 : Appellate Tribunal-Appeals-Monetary limits-Low tax effect-Appeal of Revenue is dismissed.[S. 253 (2)]

S. 251 : Appeal-Commissioner (Appeals)-Powers-Commissioner (Appeals) directing Assessing Officer to verify and allow claim-Not tantamount to setting aside or remanding matter to Assessing Officer-No violation-Order is up held-Other issues matter is remanded to the Assessing Officer. [S.54F, 69, 251 (1)(a)]

S. 153A: Assessment-Search-Credit card payments-Unexplained investments-No incriminating material found in search-Deletion of addition by CIT(A) is affirmed-Income of any other person-Presumption as to books of account and articles or things could not be extended to material of different person.[S.69, 132, 132(4A), 153C]

S. 145 : Method of accounting-Rejection-No specific defect in books of account-Rejection is not justified-Re payment of sundry creditors in next year-Addition is not justified.[S. 68, 145(3)]

S. 145 : Method of accounting-Rejection of books-Books not updated as on date of survey and discrepancies between stocks and cash physically found-Rejection is proper-Sale of jewellery-Cash received-Genuineness of transaction not proved-Addition is affirmed-Levy of interest is mandatory. [S.68,133A, 234B, 234C]

S. 145 : Method of accounting-Rejection of books of account-Without identifying any specific lacuna rejection of books of account is unjustified-Cash credits-Survey-Cash sales-Deposited in to bank-No Discrepancies found in stocks and purchases-Addition based solely on statement of third party-Opportunity for cross-examination not granted-Addition is deleted.[S. 68, 133A, 145(3)]