S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Income from offshore supply of plants, equipments, spares, etc.-Assessee has furnished evidence to show that the global profit rate in the paper division is 3 per cent the estimation of profit at 5% by the CIT(A) cannot be accepted-Issue is restored to the AO for de novo adjudication-DTAA-India-Germany.[Art. 5]

S. 2(14)(iii) : Capital asset-Agricultural land-Land situated outside the Municipal limits-As per the last Census i.e., the Census of 2011, Zirakpur had a population of 95,443-Land situated more than four kilometers away from the Municipality Limits of Zirakpur-Sale consideration is not taxable. [S. 45]

S.271D: Penalty-Takes or accepts any loan or deposit-Metal deposits-Gold or silver in physical form followed by corresponding journal entries made in the books of account terming them as unsecured loans-Penalty is not leviable.[S. 269SS]

S. 271B : Penalty-Failure to get accounts audited-Legal representatives-Death of assessee-Penalty is not leviable on legal representative-Penalty is deleted.[S.44AB, 159(1), 159(4), 274(1)]

S. 271(1)(c) : Penalty-Concealment-Capital gains-Admitted the claim as bogus-Admitted in affidavit-The admitted claim was not shown as income in response to notice issued under section 148 of the Act-Levy of penalty is affirmed. [S. 10(38), 45, 132(4), 139,148]

S. 270A:Penalty for under-reporting and misreporting of income-Difference between interest income offered to tax and income reported in Form No. 26AS-Disallowance of exemption-Penalty is deleted. [S.10(10), Form No 26AS]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny-Genuineness of expenditure-Wages and labour charges-Contractor, PAN and GST number, copy of Invoices, copy of the ledger account, payment details and the TDS on the payment made are on record-Contractor has not filed the return-The order passed by the AO cannot be held to be erroneous insofar as prejudicial to the Interest of the Revenue. [S.194C]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Audit objection-AO has conducted the required enquiry and not violated any of the conditions mentioned for revision of order as required by Expln. 2 of S. 263- Revision order is quashed. [S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Project completion method and percentage completion method-Accounting method-Guidance note-Assessing Officer has verified in the original assessment proceedings-Revision order is set aside.[S. 143(3), 145]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Survey-Specific query on undisclosed income in the course off assessment proceedings-Deeming provision is not applicable-Revision is not justified [S. 68, 69,69D, 115BBE, 133A]