S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Providing services of qualified motor racing drivers to teams participating in racing championships-Athlete-Details of actual duration of drivers’ stay in India in connection with race, time taken for preparation, finalization and conclusion and certificate of drivers’ arrival in India and departure in relation to event not furnished-Matter Remanded-DTAA-India-Switzerland. [Art. 5, 16]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Non-Resident Bank-Banking Company incorporated in Korea-Interest paid to head office-Allowable as deduction-Interest paid by PE to head office could not be brought to tax in hands of assessee-bank, even though it was allowed as deduction in computation of profits attributable to PE. [Art. 7(2), 11]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Business service agreement (BSA)-Activities are interconnected-Matter was remanded-DTAA-India-Norway. [Art. 5(2)(1)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Profits derived from baggage screening services and aircraft handling services provided to other airlines-Will not come within ambit of ‘other activity directly connected to such transport-Not covered under article 8(1)-Technical Pool (IATP)-Services from airlines on reciprocal basis, profit derived from providing baggage screening services and aircraft handling services to other airlines as a participant of IATP pool would be covered under article 8(1) read with article 8(4) DTAA-India-USA. [Art.7, 8(1),8(2), 8(4)]

S. 5 : Scope of total income-Accrual of income-Receipt of tuition fees-Services rendered next year-Income taxable in the year in which the service was rendered. [S. 4,5(1)(b), 145]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Trading-Not furnished supporting documents-Matter remanded-DTAA-India-Japan. [Art. 5(7)(a)]

S. 4 : Charge of income-tax-Subsidy-Industrial promotion scheme-Capital receipt. [S. 28(i)]

S. 4 : Charge of income-tax-Industrial undertakings-Incentive Scheme-Subsidy Intended to encourage Industrialization of State-Capital in nature. [S.80IB]

S. 4 : Charge of income-tax-Co-Operative Sugar Factory-Sale of sugar at concessional rate to members-Matter remanded to the Assessing Officer. [S. 2(24)]

S. 4 : Charge of income-tax-Firm-Partner-Double taxation-Wrong person assessed-Sale to partner without registration in earlier years-Registration deed in latter years-taxable in the year of registration-Partner declaring the income is his hands and paying taxes-Department entitled to tax income in hands of correct person-Partner at liberty to take remedial action for exclusion of amount from his total income. [S. 2(24), 145, Registration Act, 1908, S. 17(1A) 49]