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]

S. 4 : Charge of income-tax-Capital or revenue-Subsidy-Incentive to encourage development of rural economy-Exemptions from payment of Sales tax/Entry Tax/Electricity dues-Capital receipt-Forfeited amount received in respect of preference shares-Credited receipt in capital reserve account-Capital receipt. [S. 5, 28(i)]