S. 139 : Return of income – Delay in filing revised return- Amalgamation – Approval by NCLT – Revised return filed after due date of filing of return is irrelevant- Not required to seek condonation of delay by CBDT [ S. 119(2) (b) , 139 (5) , 170 ]

S. 69C : Unexplained expenditure – Bogus purchases – Sales accepted – The AO is directed to restrict the addition to the extent of lower GP declared by the assessee in respect of bogus purchases as compared to G.P. on normal purchases. [S.68 ]

S. 148 : Reassessment – Notice – Notice sent at address available in PAN database returned – Communication had to be delivered at address of assessee available with banking company – No service of reopening notice – Order making additions unjustified. [S. 147, 282 , R, 127 , Art .226 ]

S. 80HHC : Export business – Interest income assessed as business income is to be included from the profits and gains of business for the purpose of section 80HHC. [S. 80HHC]

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Charges for flight simulator usage and other flight training to cockpit crew and pilots- Not liable to deduct tax at source – DTAA- India-UAE [ S. 9(1)(vi) 195 , Art .12 ]

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Training of pilots and cabin crew – Can not be assessed as fees for technical services or royalties – Not liable to deduct tax at source – OECD Model Convention , Art, 12 [ S.9(1)(vi) , 195 ]

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services – Inspection charges – Not liable to deduct tax at source -DTAA-India – Indonesia [S.195 , Art. 12 ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Non-resident – Import of coal- No business connection- Income cannot be deemed to have accrued or arose in India in transaction of export of coal to assessee in India- Not liable to deduct tax at source-OECD Model convention , Art 7 . [ S.195, 201 (1) 201(IA) ]

S. 268A : Appeal-Monetary limits-CBDT Circular No. 17/2019, dated 8-8-2019 revising/enhancing minimum threshold limit to tax effect of Rs. 50 lakhs would also be applicable to pending appeals before Tribunal. [S. 253]

S. 251 : Appeal-Commissioner (Appeals)-Power of enhancement Not competent to enhance assessment by taking an income which income was not considered expressly or by necessary implication by AO. [S. 45, 54F, 68, 147]