S. 14A : Disallowance of expenditure – Exempt income – Shares held as stock-in trade -Interest expenditure – Value its stock at cost or market value, whichever was lower -Matter remanded .[ S. 36(1)(iii), 115JB, R.8D (ii) ]

S. 11 : Property held for charitable purposes – Micro finance activity — Not charitable in nature — Not entitled to exemption [ S. 2 (15) ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Royalty — Fees for technical services —Reimbursement of expenses- Held to be not taxable – DTAA-India – Singapore [ Art 5 (2) 12 ]

S. 4 : Charge of income-tax – Diversion of income by overriding title — Revenue sharing agreement- Holding company – Expenditure incurred towards services obtained from its holding company allowable as deduction .

S. 271C : Penalty – Failure to deduct at source – Non -resident – Short deduction of tax – levy of penalty is not justified when the assessee has deducted tax at source under S. 194IA instead of S 195 of the Act – Levy of penalty was deleted . [ S. 194IA ,195,201, 201(IA), 273B ]

S. 147 : Reassessment –With in four years- Client code modification- Reassessment notice is held to be bad in law. [ S. 68, 69C ,115BBE 143(1) 148 ]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record – Capital gains – Distribution of capital asset -Retirement – Amount credited to Partner’s capital account prior to retirement for goodwill whether taxable as capital gains with cost of acquisition as per sec. 55(2)(a) as NIL – Miscellaneous application of the revenue is dismissed [ S.45(4) 55(2)(a) ]

S.147: Reassessment – Notice – Additional ground -AO can issue the notice u/s 143(2) only after filing of return of income in response to notice under section 148 of the Act – Prior issue of notice before such return is redundant therefore reassessment cancelled and quashed [ S.143(2) 148 151 292BB ]