S. 4 : Charge of income-tax-Principle of mutuality — Payments were reimbursement and exempt from taxation and covered by principle of mutuality.

S. 4 : Charge of income-tax-Capital or revenue-Duty credit entitlement under served from India Scheme-credit only be utilised by set off against duties arising on purchase of capital goods or spare-Capital in nature.[S. 28(i), 32, 43(1)]

S. 2(22)(d) : Dividend-Any distribution to its share holders on the reduction of its share capital-Buy back of shares-Scheme of arrangement or compromise-There was a capital reduction and distribution out of accumulated profit of company to its shareholders, same would entail release of all or part of assets of a company on reduction of capital and would attract provisions of section 2(22)(d), and consequently, assessee was liable for payment of DDT under section 115-O. [S. 115O, 115QA, Companies Act 1956, S. 77, 77A 100 to104, 391, 292, 393]

S. 271D : Penalty-Takes or accepts any loan or deposit-Ignorance of law and bona fides-Non-Resident directors not material-Not mere technical violation in case of companies-Levy of penalty Justified. [S.269SS, 269T, 271E]

S. 271AA : Penalty-Failure to keep and maintain books of accounts-Documents-International transaction-Transfer pricing-Non-compliance of provisions occurred due to opinion given by Chartered Accountant-Reasonable cause-Penalty unsustainable.[S.40A(2)(b), 92D, 92E, 273B]

S. 271(1)(c) : Penalty-Concealment-Additional depreciation-Claim not sustained by authorities-Penalty is not leviable.[S. 32]

S. 271(1)(c) : Penalty-Concealment-Prosecution on same facts quashed-No ground for levy of penalty. [S. 276C(1), 276D, 277]

S. 270A : Penalty for under-reporting and misreporting of income-Income tax refund-Offered in the course of assessment-Non-declaration of interest cannot be said to be under-reporting of Income. [S. 143(3), 274]

S. 270A : Penalty for under-reporting and misreporting of income-Notice not mentioning under which limb of section notice issued-Proceedings unsustainable. [S.270A(9)]

S. 270A : Penalty for under-reporting and misreporting of income-Change of head of income-Rental income-Explanation is not found to be false-Penalty is deleted.[S. 22, 23,24(a), 270A(6)]