S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Management fees-Indian subsidiaries-Most favoured Nation (MFN) clause-Not taxable as fees for technical services-Training services-Matter remanded-DTAA-India-Sweden. [Art. 10, 12(4)(b)]

S. 9(1)(ii) : Income deemed to accrue or arise in India-Salaries-Dependent personal services-Non-Resident-Salary and allowance outside India-Failure to produce tax residency certificate-Not taxable in India-DTAA-India-Belgium. [S. 5(2), 15, 90(4), Art. 15(1)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Re insurance business-Service / dependent-Agreement with Indian subsidiary-DTAA-India-Switzerland. [Art. 5, 7]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Reimbursement of software licence fee-Not liable to be taxed as royalty-DTAA-India-Swedish. [Art. 12]

S. 6(1) : Residence in India-Individual-Out side India for a period more than 182 days-Salary income received by assessee outside India from a foreign employer for services rendered outside India could not be brought to tax in India. [S. 5]

S. 6(1) : Residence in India-Individual-Out side India for a period more than 182 days-Salary income received by assessee outside India from a foreign employer for services rendered outside India could not be brought to tax in India. [S. 5]

S. 5 : Scope of total income-Accrual of income-Sale proceeds-Memorandum of understanding (MoU) with SIPL to invest in project to be executed by SIPL-Agreement for sale-Project was not completed-whole profit cannot be taxed in the first year of execution of MOU-Matter remanded. [S. 145]

S. 2(14) : Capital asset-Rights or interest in a property-Period of holding is to be reckoned from date of first agreement, while calculating capital gains. [S. 2(42A), 2(42B), 45]

S. 24(3) : Benami Transactions-Amendment Act 2016-Jurisdictional High Court declaring amendment to have no retrospective effect-Operation of order stayed by Supreme Court-Binding precedent-Interpretation-Decision of High Court not set aside and to be followed by same High Court precedent-Effect of stay order by Supreme Court-The authorities were not to take any further steps in the matter till the disposal of these writ petitions and the petitioners shall not sell, otherwise transfer, deal with, encumber or part with possession of the properties in question till the disposal of the writ petitions-An order of stay in a pending appeal before the Supreme Court does not amount to any declaration of law but is only binding upon the parties to the proceedings and at the same time, such interim order does not destroy the binding effect of the judgment of the High Court as a precedent because while granting the interim order. [S. 24(5), 26(7), Art. 226]

Art. 141 : Covid-19-Limitation-Extension of period-Order dated March 8, 2021 restored with clarifications-Period from March 15, 2020 till March 14, 2021 excluded and further clarification given [Art, 142, Arbitration and Conciliation Act, 1996 S, 23(4), 29, Commercial Courts Act, 2015, S. 12A, Negotiable Instruments Act, 1881,S.138,any other law, which prescribes limitation]