S. 10(23C) : Educational institution-Fresh claim-Educational institution wholly and substantially financed by Government-Matter remanded to the Assessing Officer for fresh adjudication. [S.10(23C)(iiiab), 10(23C(iiiad), 12A]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Business of providing hotel service-Franchise Agreement (MFA)-Amount received by assessee under MFA could not be treated as royalty/FTS/FIS amount received by assessee under MFA could not be treated as royalty/FTS/FIS-DTAA-India-USA.[Art.12]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Marketing support services-Fees for included services-Cannot be treated as Fees for included services-DTAA-India-USA. [Art. 12(4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-No permanent establishment in India-Fees for technical services-Providing hotel related services-Marketing, advertisement and other services to customers in India-Not taxable as fees for technical services-DTAA-India-USA [S. 9(1)(i), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Service Agreement-Service Agreement was independent of royalty earned in terms of License Agreement, same was not taxable in India as FTS or royalty-DTAA-India-Netherland-Reimbursement of expenses-Not taxable as FTS Management service fee-Matter remanded for de novo consideration.[S. 9(1)(vii), Art. 12(5)(a)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Purchase of software-Non transferable and non exclusive grant of license-Not royalty-Not liable to deduct tax at source-DTAA-India-USA.[S.195, 201, Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Data line charges-Neither royalty nor fees for technical services-Reimbursement of expenses on actual cost basis-Not chargeable to tax-Not liable to deduct tax at source-DTAA-India-USA [S.9(1)(vii, 195, 201, Art. 12]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Interest paid by branch to head office-Borrowed by PE-Allowable as deduction-DTAA-India [Art. 7, 11]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Interest paid-Head office-Cannot be brought to tax even though it is allowed as deduction in computing profits attributable to PE-DTAA-India-Korea [Art. 7, 11]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Income from sale of tickets-Profit derived from operation of ships or aircraft in international traffic was liable to be taxed in contracting state in which place of effective management of enterprise was situated, which was Bhutan-DTAA-India-Bhutan [S. 90, Art. 8]