S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Sale of software products to Indian distributors for onward resale to end-users-Product simpliciter facilitating digital security and not for rendering technical services, such income was not taxable in India as FTS-DTAA-India-Ireland [Art. 12 (3)(b)]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping, Inland waterways transport and air transport-International traffic-UK tax resident airline-Received delivery order charges in connection with transportation of passengers, mail, livestock and goods by air in international traffic-Considered directly connected with operation of aircraft under Article 8(3) of India-UK DTAA and thus, would not be taxable in India-DTAA-India-UK [Art. 8]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping, Inland waterways transport and air transport-International traffic-Operation of ships in international traffic-Multiple ports in India-Benefit of Article 8 of India-UAE DTAA was to be extended to entire freight receipts irrespective of whether earnings were relating to feeder vessels or by ships in international traffic-Profit derived from shipping business as envisaged under article 8 of India-UAE DTAA and was not taxable as business profit in India-DTAA-India-UAE [Art 8]

S. 4: Charge of income-tax-Capital or revenue-Compensation received for underperformance of wind turbine generators (WTGs)-Capital receipt. [S.28(i)]

S. 4: Charge of income-tax-Capital or revenue-Grants-Capital reserve account-Road project-Infrastructure development-Grants/contributions from State Government for completion of road projects undertaken by it on BOT basis-Grants/contributions were a capital contribution by State Government towards the cost of projects-Not taxable as revenue receipts. [S. 28(i), 145]

S. 2(22)(e): Deemed dividend-Refundable rental security deposit from tenant-Cannot be assessed as deemed dividend-Matter remanded.

S. 2(22)(e): Deemed dividend-Deemed dividend-Loan to firm where partners held substantial interest in lender company-Assessee not a shareholder-Advances are not chargeable as deemed dividend.

S. 2(14)(iii): Capital gains-Land beyond 8 km from municipal limits-Held, not a capital asset-Agricultural income supported by records-Additions deleted. [S. 10(1), 153A]

S. 272A: Penalty-Failure to answer questions-Sign statements-Furnish information-Defaulted in timely furnishing of information but ultimately submitted all requisite details which were duly considered in framing assessment-lapse was only a technical/venial breach-Penalty was not justified.[S. 10(23C), 139, 272A(1)(d)]

S.271D: Penalty-Takes or accepts any loan or deposit-Limitation-Penalty proceedings under section 271D were initiated during reassessment by issuing a show-cause notice on 17-8-2022-Penalty order was passed on 29-3-2023 beyond the limitation period under section 275(1)(c)-Penalty was barred by limitation and was not sustainable. [S. 148, 269SS, 275(1)(c)]