S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Specified domestic transaction-Comparable-Functional similarity-Company engaged in marketing research and management activity was comparable to assessee-company, investment advisory services provider. [S. 260A]

S. 90 : Double taxation relief-Foreign tax credit (FTC)-Form-67 filed before completion of assessment and after due date specified for furnishing return under section. 139(1)-Rejection of FTC is not justified-DTAA-India-Australia [S. 91, 139(1), 143(1), Rule 128, Form-67 Art. 24, Art. 226]

S. 48 : Capital gains-Mode of Computation-Sale of shares gifted by promoters-BIFR cannot sanction any modification to scheme directing the Income tax department to give further tax concession without department being consenting to grant additional concession-SLP is granted against the order of High Court. [S. 45, Sick Industrial Companies (Special Provisions) Act, 1985, 3(1)(o), 17, 18, 22A, Art. 136]

S. 44BB : Mineral oils-Computation-Presumptive tax — Non-resident-Service tax collected-Not includible in gross receipt-SLP of Revenue is dismissed [S.44BB(2)]

S. 37(1) : Business expenditure-Capital or revenue-Hotel-renovation, refurbishment and repairs-Consultancy payments-Allowable as revenue expenditure.[S.28((i)]

S. 10AA : Special Economic Zones-Constitutional validity-Explanation after sub-section (1) of section 10AA, inserted by amendment with prospective effect from 1-4-2018, applicable in respect of assessment year 2018-19 and subsequent years-Constitutionally valid. [Art. 14, 19(1)(g), 226 265]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of telecom equipment’s. i.e. mobile handsets-Supply of articles or goods-Not taxable as royalty-Review petition against SLP is dismissed-DTAA-India-China. [S. 9(1)(i), Art, 12]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Capital gains-Shares-Not liable to be assessed as capital gains-Explanations 6 and 7 to section 9(1)(i) has to be treated retrospectively as it have to be read along with Explanation 5 which operates from 1-4-1962-OECD Model Convention, Art. 13 [S. 260A]

S. 220 : Collection and recovery – Assessee deemed in default – Stay – Pendency of rectification application- Pendency of appeal before CIT(A)- Stay is granted on entire demand till disposal of appeal . [ S.2(15), 12A, 154 , 220(6), 250 , Art. 226 ]

S. 48 : Capital gains –Mode of Computation – Sale of shares gifted by promoters – BIFR cannot sanction any modification to scheme directing the Income tax department to give further tax concession without department being consenting to grant additional concession .[ S. 45 , Sick Industrial Companies ( Special Provisions ) Act , 1985 , 3(1)(o) , 17 , 18 , 22A, Art. 226 ]