S. 11 : Property held for charitable purposes – Registration granted prior to the initiation of reassessment proceedings – Exemption cannot be denied [ S.12A, 147 , 148 ]

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Subscription revenue received by the assessee to be in the nature of royalty and bringing it to tax in India.-DTAA -India -UK [ S.90 , 115A, Art , 13 (6) ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Providing support services – Taxable at the rate of 20% on gross basis – DTAA-India -USA [ S.9 (1)(vii) ,44AD, 115A, 195 ( 2), Art, 12 ]

Kar Vivad Samadhan Scheme ,1998

S. 90 : Tax arrear – Since the revenue had appropriated the amount against tax liability for the Assessment year 1987 -88 computation / calculation of penalty and interest for the said assessment year in certificate of intimation dated 26 -2 -1999 was not justified [ Art . 226 ]

S. 271(1)(c) : Penalty – Concealment –Capital gains – Year of taxability – Offered on the basis of consideration received – In response to notice u/s 148 the entire consideration was offered and accepted – levy of penalty is held to be not justified for furnishing in accurate particulars of income [ S.45 , 147 ,148 ]

S. 271(1)(c) : Penalty – Concealment –Capital gains – Year of taxability – Offered on the basis of consideration received – In response to notice u/s 148 the entire consideration was offered and accepted – levy of penalty is held to be not justified for furnishing in accurate particulars of income [ S.45 , 147 ,148 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Set off of carried forward loss (Unabsorbed portion of depreciation) [ S.68 71 ,115BBE [

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Set off of carried forward loss (Unabsorbed portion of depreciation) [ S.68 71 ,115BBE [

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Shipping business – Non-residents –Failure to deduct tax at source – Revision is held to be not valid – Order of Appellate Tribunal is affirmed [ S. 40(a)(ia) , 143 (3) , 172 194C , 195 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Unexplained investments -Increase in capital investment – Specific question was raised in the original assessment proceedings – Revision is held to be bad in law [ S.69 ]