S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Supply of telecommunication hardware with software-Receipt is not taxable as royalty-Not liable to pay interest u/s. 234B-DTAA-India-USA. [S. 90, 195, 234B, Art. 7, 12]

S. 4 : Charge of income-tax-Subscription received by assessee from members towards holidays membership schemes—Entries in the books of account is not conclusive-Collective investment schemes(CIS)-Advances for sales-Deposits-The deposits received from the members cannot be treated as revenue receipt-Capital receipt.[S.40(a)(ia), 145, 194A, 195]

S. 4 : Charge of income-tax-Capital or revenue-Business income-Compensation-Other payments-Income chargeable to tax-Compensation for termination (nonrenewal) of professional contract-Profession-Retrenchment-Freelance journalist-Compensation being capital receipt is not taxable. [S. 4, 28(ii)(e), 32(1)(iv), 56(2)(xi), Industrial Relations Code, 2020, S. 2(ZA)]

S.271D: Penalty-Takes or accepts any loan or deposit-Book adjustment entries-No violation of section. 269SS-Penalty is deleted. [S. 269SS]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Reassessment-Lack of proper enquiry-Issues not subject-matter of reassessment-Issue which is not subject matter of reassessment, Commissioner cannot direct the Assessing Officer to carry out the enquiry as suggested by the Commissioner. [S. 37(1), 40A(2)(vi), 40A(2)(b), 147, 148]

S. 254(1): Appellate Tribunal-Powers-Cross objection-Performance guarantee-Deposit-Jurisdictional issue-Ground raised orally-Validity of reassessment-Respondent can raise the issue orally-CIT(A) deleted the addition on merits-Revenue appeal-The Respondent can raise the grounds of validity of reassessment-Rule 27 of the ITAT Rules, 1963, does not propose raising the objection in writing-The respondent is well within his right to raise the ground orally-Reassessment is quashed on change of opinion. [S. 37, 69, 147, 148, ITAT R.1963, 27]

S. 250 : Appeal-Commissioner (Appeals)-Dismissal of appeal-Ex parte order-CIT(A) is directed to decide the appeal on merits. [S.246A]

S. 206C : Collection at source-Trading-Forest produce-Minor forest product-Forest product-Vegetable and animal origin, such as grasses, bamboos, canes, tans, dyes, oils, gums, resins, fibres, flosses, leaves, drugs, spices, poisons, edible products and animal prod-Minor forest products-Not liable to collect tax at source Agricultural product in the nature of Mahua Oil, Puhad, Ambadi, Dolma Kanji, Ratanjot and the cattle feed (Bhusa and Khal), etc. is not liable to collect tax at source. [S. 206C(1), 206C(6A), 206C(7) ]

S. 194LBC : Deduction at source-Investment in securitization trust-Assessee in default-Excess Interest Spread by securitization trust group-Pass through certificates by originator-No liability to deduct TDS from the payment of Excess Interest Spread by securitization trust-Not an assessee in default. [S.115TCA, Explanation (d), 201(1)]

S. 194C : Deduction at source-Contractors-Freight charges to transporters on behalf of third party under tripartite agreement-Provision is not attracted. [S. 201(1), 201(IA) ]