S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Cost Contribution Agreement (CCA) with group company, incorporated in UK, for provision of Business Support Services (BSS)-Services were in nature of managerial services and not technical services-Not taxable as fee for technical services (FTS)-The amount received by assessee, a UK based company, towards usage charges of software was not payment of royalty for use of copyright in computer software, and same did not give rise to any income taxable in India-DTAA-India-UK [S. 9(1)(vi), Art. 13]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Make available-Provided/sublicensed software to entities in financial service sector and also provided maintenance, support and training services and received fees towards same-No PE in India-Recipient, fees received by assessee could not be taxed in India-Additional services related to implementation and migration of software to its Indian customers-Business receipts-No PE in India-Not taxable-DTAA-India-Singapore. [S.9(1)(i), Art. 12 (4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Supply of drawings and designs-Not assessable as fees for technical services-Supervisory services-Contract competition method-Remanded to the Assessing Officer-DTAA-India-Germany. [S. 9(1)(vi, 147, Art. 7, 12]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Fees for provisions for other related services-Software itself is not taxable-Addition made for other related services is deleted-DTAA-India-UK.[S. 9(1)(vi), Art. 13]

S. 5 : Scope of total income-Inter-Corporate Deposits (ICDs)-Non-Performing Assets (NPAs) as per Prudential Norms issued by RBI-Possibility of recovery is almost nil-Cannot not be treated to have accrued to assesse. [S.4 43D]

S. 4 : Charge of income-tax-Joint development agreement-Income offered to tax-Making once again addition is lead to double addition-Order of CIT(A) deleting the addition is affirmed.

S. 4 : Charge of income-tax-Reimbursement of expenses incurred by JV firm-Order of CIT(A) deleting the addition is affirmed.

S. 69C : Unexplained expenditure – Bogus purchases – Information from Investigation Wing – Addition restricted to 4% justified – Additional ground of Revenue to disallowance at 100% of alleged bogus purchases is rejected – No justification for 100% disallowance in absence of suppression of sales –Books of account not rejected – PCIT v. Kanak Impex (India ) Ltd [2025] 172 taxmann.com 283/ 474 ITR 175 (Bom)( HC) is referred . [ S.145, 147 , 148 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Faceless assessment – Notice is issued by the Jurisdictional Assessing Officer – On writ the Court set aside the notice issued under Section 148 and all other proceedings/orders emanating therefrom- Honourable Court has granted liberty to the Revenue to revive the order simply by moving a Praecipe before this Court- The Court also observed that once the Petition is revived and restored, the same would have to be decided on its own merits considering that several other issues are also raised in challenging the Notice issued under Section 148 [ S. 148 ,Art. 226 ]

S. 271(1)(c) : Penalty – Concealment – Disallowance of deduction- Method of accounting – Plausible interpretation of law – No malafide intention – Disclosed all relevant facts and no false statement –Penalty is deleted . [S. 43B , 145 , 260A ]