S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-User of software-Payment received cannot be taxable as fees for technical services or royalty-DTAA-India-Netherland [S. 9(1)(vi), 90, Art. 12(5)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-None of the employees came to India for the purpose of either development or sale of or any activity related to development and sale of RPA software platform-No permanent establishment-No income attributable on sale of software licence-Additional ground-Rejected-DTAA-India-USA. [Art. 5, 12]

S. 271D : Penalty-Takes or accepts any loan or deposit-Sale of immoveable property-Stock in trade-Sale deed registered-No deliberate defiance of law-Penalty is deleted. [S.269SS]

S. 271AAB : Penalty-Search initiated on or after Ist day of July 2012-Cash payment-Recorded in balance sheet-Cannot be held to be undisclosed-Additional ground-Legal issue-Matter remanded to the CIT(A). [S. 270A,274, ITAT R. 27]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Additional depreciation-Revision order is quashed.[S. 32, 115JB, 147, 148]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Conversion firm to limited liability partnership-Firm dissolving on date of conversion-Income earned recorded in hands of Limited Liability Partnership-Tax deducted at source appearing in Firm’s name only allowed to firm and not limited liability partnership-No double grant of credit-Revision is not valid. [S. 142(1) 143(2)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Income from other sources-Interest-Debentures redeemed after nine years-Conversion of debentures into equity shares-Entire interest deemed to be received by debenture holder upon conversion of debentures into equity shares in year of conversion–Assessing Officer accepted the return-Revision is justified.[S. 2(24)(iv),47(x),49(2A),56,143(1)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Granted registration and income is applied for designated purposes-Exercise of revisional jurisdiction is not valid. [S. 11, 12A, 12AA]

S. 254(2A): Appellate Tribunal-Stay-Cash credits-Failure to prove genuineness of transaction-Rejection of stay application is justified. [S. 68, 133A, 254(1)]

S. 254(1) : Appellate Tribunal-Powers-Delay of 551 days in filing an appeal before CIT(A) is condoned-Directed to pay cost of Rs 1000 to each appeal to be paid to Prime Minister’s National Relief fund with in a period of 30 days form the date of the order. [S. 147 246A, 250(6), 271AAC(1), 271B 271F]