S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection–Cannot be considered as constituting Agency PE of that assessee-DTAA-India–Mauritius. [Art. 5(5), 8]

S. 279 : Offences and prosecutions–Compounding–Review–Compounding fees was levied 5% as treating the same as second application–Review petition was dismissed. [S. 201(1), 276B, 279(2), CPC, S. 114]

S. 271(1)(c) : Penalty–Concealment–Capital gains-Merely because claim is not accepted levy of penalty is held to be not justified. [S. 45, 54EC]

S. 260A : Appeal-High Court-Issue not contested cannot be agitated before the High Court. [S. 37(1)]

S. 245D : Settlement Commission–Full and true disclosure– Additional income disclosed–Justified in holding that there was a full and true disclosure-Writ petition of revenue is dismissed . [S. 133A, 245C, 245D(4), Art. 226]

S. 234A : Interest-Default in furnishing return of income-Waiver of interest–Or otherwise–Delay in filing of return was due to impounding of documents in the course of survey.[S. 234B, 234C, Art. 226]

S. 225 : Collection and recovery-Stay of proceedings–Pendency of appeal–Recovery of penalty is stayed till the disposal of the appeal. [S. 271(1)(c), Art. 226]

S. 221 : Collection and recovery–Penalty-Tax in default –Delay in remitting the Tax deducted at source-Survey – Financial stringency not proved-Levy of penalty is held to be justified. [S. 133A, 201]

S. 197 : Deduction at source-Certificate for lower rate–Application for lower tax deduction is allowed, subject to certain conditions. [S. 194-C, 194-H, 197, 201(1), 201(1A), 264, Art.226]

S. 194LA : Deduction at source–Agricultural land-Compensation on acquisition of certain immoveable property-From report of Halqa Patwari it was evident that land of assessee acquired by Government was ‘Gairmumkin’ in nature, and same was not agricultural land, compensation received by assessee in pursuance of land acquisition proceedings was subject to TDS [S 2(14)(iii), 10 (37), 45, 119, 237, Art. 226]