S. 5 : Scope of total income–Interest on NPAs not taxable on accrual basis in the hands of a non-banking institution. [S. 43D, 145, RBI Act, ]S. 45Q]

S. 2(31) : Person – Status of an entity incorporated abroad has to be determined even in India, according to the law of the country where the entity is incorporated. [S. 74, 80, 139(3)]

S. 2(22)(e) : Deemed dividend- Income cannot be taxed in the hands of the shareholders unless it is shown that the monies have been received by them.-Alleged admission- Matter remanded [ S.254 (1) ]

S. 2(14)(iii) : Capital asset – Agricultural land – land sold being situated within municipal limits of Thanesar City – AO rightly considered land as non-agricultural land — Contention that benefit of S 54F is to be given could not be accepted since it was not raised before any of the lower authorities. [S. 45, 54F]

S. 264 :Commissioner – Revision of other orders – Amount mistakenly paid as tax- Revision is not maintainable – Duty of the revenue to refund the amount- Substantial justice should prevail over technical considerations . [ S.119 ]

S. 264 :Commissioner – Revision of other orders – Application for condonation of delay cannot be dismissed for technical reasons —Principle of substantial justice- Matter remanded . [ S.80P ]

S. 158BFA : Block assessment – Penalty – Legal representative-
No proceedings for penalty for concealment of income was initiated against person prior to his death — Penalty cannot be imposed on legal representatives .[ S. 158BC, 159 271(1)( c ) ]

S. 147 : Reassessment –With in four years- Change of opinion- Details were submitted in the original assessment proceedings – Reassessment for purpose of verification and investigation is held to be not valid .[ S.148 ]

S.147: Reassessment-After the expiry of four years- Failure to disclose material facts – Reassessment notice is held to be valid- Disputed questions of facts — Alternative remedy of appeal – Notice of reassessment is held to be valid .[ S.148 , 151 , Art .226 ]

S.147: Reassessment-After the expiry of four years- No failure to disclose material facts – Denial of exemption in subsequent year is not aground for reassessment .[ S. 10A, 148 ]