S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Merely provided alloys, lease rentals received for such leasing out of alloys could not be treated as royalty-DTAA-India-USA. [Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Right to use of copy right in a program-Information products and services-Not royalty-DTAA-India-USA. [Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Consideration for resale / use of computer software-Payment is not payment of royalty-Not taxable in India-Not liable to deduct tax at source-DTAA-India-USA. [S. 195, 201(1), 201(IA), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Business of transmitting telecommunication signals to/from its customers-Income earned was not in nature of royalties-Not liable to tax in India-DTAA-India-USA. [Art. 12(3)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Support service-Outsourcing of work to India would not give rise to a fixed place PE-DTAA-India-Mauritius. [Art. 5]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Shipping business-Indian company an agent of independent status-Cannot be assessed as Agency PE of the assessee-DTAA-India-Mauritius. [Art. 5(5)]

S. 245 : Refund- Set off of refunds against tax remaining payable -Adjustment made without prior intimation is held to be bad in law .[ Art , 226 ]

S. 80IB(10) : Housing projects- Two flats excess of the prescribed limit of 1500 sq.ft – Pro rata deduction in respect of eligible flats not exceeding prescribed limit is eligible – Interpretation of taxing Statutes – When the language of a statute is unambiguous and admits of only one meaning, no question of construction of a statute then arises .[ S. 260A ]

S. 69C : Unexplained expenditure –Income from undisclosed sources – Bogus purchases -Civil works – Road construction -Information from Sales Tax Department – Order of Tribunal estimated profit of 12.5% on unexplained and non -genuine purchases is affirmed by High Court .[ S. 37(1), 143(3), 260A]

S. 36(1)(vii) :Bad debt – Pendency of dispute – Lease rental – Depreciation -Once a business decision has taken to write off a debt as a bad debt in books of account should sufficient to allow the claim as bad debt [ S. 36(2) ]