S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Payments were made to UAE company to carry out services of project specification study, preparation of tower designs, preparation of structural drawings of tower, preparation of tower test data documents etc.-Not royalty-Not liable to deduct tax at source-DTAA-India-UAE. [S. 201(1), 201(IA), Art. 7, 12]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Limited Liability Partnership (LLP) and tax resident of UK-legal services to its clients worldwide-Entitled to benefit of article 4(1) of India-UK DTAA in respect of income generated from professional services rendered in India which had been taxed in UK-providing legal services to its client worldwide was not FTS-Employees of assessee, non-resident LLP, for rendering services in India stayed for only 17 days-Independent personnel services or independent activity-DTAA-India-UK [S.9(1)(vii), Art. 4(1), 5, 13, 15]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Projection of business in India-Under control and guidance-Considered as fixed place PE of assessee company-Attribution of profit PE is taxable in India-DTAA-India-USA [Art. 5]

S. 145: Method of accounting — Securitisation transactions — Sale to special purpose vehicle against lump sum consideration equal to book value – Offering excess interest spread to tax on proportionate basis as and when accruing over tenure – Method accepted by Revenue — Rule of consistency —Addition is deleted – Real income to be assessed .

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Compounding of offence-Belated filing of application-Affidavit is filed explaining the delay-Matter is remanded to be decided on merits.[S. 276B, Art.226]

S. 279 : Offences and prosecutions-Compounding of offences-Compounding fees-Failure to deposit tax deducted at source-Subsequent offences-Compounding fee of 5 percent is affirmed-Compounding fee by all directors instead one director, directed to re examine.[S. 2(35), 276B, 278B, Art. 226]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-Penalty proceeding initiated against assessee for concealment of income was dropped-Trial Court rightly acquitted assessee. [S. 139(5), 277]

S. 271FA : Penalty-Annual information return (AIR)-Failure to furnish-Delay of 525 days-No reasonable cause-Order imposing the penalty is affirmed.[S. 273B, 285BA(1)(b), Art. 226]

S. 271E : Penalty-Repayment of loan or deposit-Limitation-Assessment order was passed on 31st Dec., 2010-Penalty order passed on 30th Dec., 2011 was barred by limitation-No substantial question of law. [S. 260A, 275(1)( c)]

S. 268A : Appeal-Instructions-Circulars-Monetary limits-Appeal of Revenue is dismissed-[WTACT, 1957, S.29]