S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Liaison office-Supply of information having preparatory or auxiliary character-Would not constitute Permanent Establishment-DTAA-India-Mauritius. [Art. 5, 2(c), 5(3)(ii)]

S. 2(22)(e) : Deemed dividend-Trade advances-Security by way of mortgage-Deletion of addition is justified. [S. 132, 153A]

. 147: Reassessment – Cash credits – Share application money – Settlement Commission accepted the returned income as per settlement petition – Reassessment notice was issued on the basis of subsequent search action in the group concern – Assessing Officer has no jurisdiction to issue notice under section 148 of the Act after passing of the order by Settlement Commission – Order of settlement commission is conclusive and cannot be reopened except as provided in that Chapter . [ S. 68 , 148 245D(4) , 245I ]

Direct Tax Vivad Se Vishwas Act, 2020

S. 4: Filing of declaration and particular to be furnished -Time Limits up to 31-3 -2021 – Appeal disposed of by Tribunal on 22-4-2021 – After disposal of appeal declaration was filed – Rejection of declaration is valid [ S. 2(1)(a), 3 , Art , 226 ]

Direct Tax Vivad Se Vishwas Act, 2020
S. 3: Amount payable by declarant – Time and manner of payment – Failure to make the payment within time prescribed – No vested right – Petition was dismissed [ S. 5 , Art , 226 ]

S. 151 : Reassessment-After the expiry of four years-Limitation-Sanction-Sanction by Additional Commissioner instead of Principal Commissioner-Taxation and other laws (Relaxation of certain Provisions) Act, 2020 only extended period of limitation and not for approval by the competent Authority-Sanction by Additional Commissioner was held to be bad in law-Reassessment notice was quashed. [S. 147, 148, Art. 226]

Direct Tax Vivad Se Vishwas Act 2020 (2020) 422 ITR 121 (St)

S. 3 : Amount payable by declarant-Credit for tax paid under Income Declaration Scheme, 2016-Denial of credit is held to be not valid-Directed the Revenue to give credit and rectify Form No. 3 issued under DTVSV Act with DTVSV rules. [Income Declaration Scheme, 2016, S. 183, 184, 185, 191, Art. 226]

S. 264 : Commissioner-Revision of other orders-Petition cannot be dismissed on the ground that the assessee has not waived the right of appeal before the Commissioner of Income-tax (Appeals). [S. 246A, 264(4), Art. 226]

S. 264 : Commissioner-Revision of other orders-Business loss or speculation-Amount voluntary agreed can also be the subject matter of revision-Rejection of revision application was not valid-Directed the Commissioner to decide on merit after considering all the submissions. [S. 43(5)(d), 139, Art. 226]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Excess depreciation-Subsidy-Revision is held to be not valid-Order of Tribunal affirmed.[S.32, 43(1), 260A]