S.14A : Disallowance of expenditure-Exempt income-No exempt income earned during the year-No disallowance can be made-When no disallowance is made addition cannot be made to book profi.t [S. 115JB, R. 8D]

S. 12AA : Procedure for registration-Trust or institution-Required to examine genuineness of institution-Denial of registration on the ground of profit was generated was not valid. [S. 2(15)]

S. 12A : Registration-Trust or institution-Bogus donation-Cancellation of registration was set aside. [S. 12AA(3)]

S. 10A : Free trade zone-Set-off losses of STP/SEZ unit against income of non-STP units-Allowed to be set off-Export turnover-Deemed export, reimbursement of expenses, expenses incurred in foreign currency, delayed export proceeds and VAT/GST would form part of export turnover-Corporate office expenses-Allowed on ad hoc percentage of 20 percent and not based on turnover of various undertakings for purpose of deductions under section 10A.[S. 80IB, 80IC]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Providing access to computer software to Indian comoany-Not royalty-Not liable to be taxed in India-DTAA-India-UK. [Art. 13, Copy right Act, 1957, S. 14, Art. 226]

S. 4 : Charge of income-tax-Interest-Interest accrued had to be utilized only for purpose of scheme-Not assessable as revenue receipt.

S. 250 : Appeal-Commissioner (Appeals ) -Procedure -Faceless Appeal Scheme – Video Conference -Natural justice – Opportunity for personal hearing not granted – Retrospective effect- Order set aside and remanded back. [ S. 250(6B) , National Faceless Appeals Scheme 2020, Rule 12(2), 12(3), 13(2) ]

S. 9(1)(i): Income deemed to accrue or arise in India – Permanent establishment – Interest will not be taxed at a higher rate- DTAA- India- Japan . [ Art, 7, 11(2)(11(6), 14 ]

S. 90: Double taxation relief – Foreign Company – discrimination allowed – Company has not made prescribed arrangement-DTAA-India -Korea . [ S. 2(22A), Art, 25(1)]

S. 144C: Reference to dispute resolution panel – Rectification application by TPO – Rectification order by DRP – Not maintainable. [ S. 144C(14), 154 ]