S. 10(23C) : Educational institution-Charitable purpose-Order of High Court affirmed-SLP of Revenue is dismissed-Delay of 247b days-Review petition is dismissed on account of delay as well as on merits. [S. 2(15), 10(23C)(iv), Art. 136]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-Sale of software-Subscription fees-Order of High Court is affirmed-SLP of Revenue is dismissed-DTAA-India-USA [S.9(1)(vii), art. 12, Art. 136]

S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Other income-Guarantee to various banks to extend credit facilities to its Indian subsidiaries-Guarantee charges were not received by assessee in respect of any debt owed to it by its Indian subsidiary-Guarantee fee would not fall within expression ‘interest’ in article 12 of India UK DTAA-Accrue-Arise-Income-DTAA-India-UK-Northern Ireland / [S. 2(28A), 5(2), 260A, art.7, 12(5), 23(3)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Liaison Office-Non-Resident company-Did not finalize and transact a business deal and activities-Liaison Office could not be said to be preparatory or auxiliary in nature, LO did not constitute Permanent Establishment of assessee-MIPL was not performing additional function, in absence of material, it could not be taken as dependant agency PE to assessee, a non-resident company-Delay of 395 days-SLP of Revenue is dismissed on account of delay as well as on merits-DTAA-India-Japan [art. 5, Art. 136]

S. 4 : Charge of income-tax-Subsidy-Capital or revenue-Bengal Incentive Scheme, 2004-Linked to establishment of new units-Capital in nature.[S.28(i)]

S. 4 : Charge of income-tax-Interest-Capital or revenue-Auction sale-Interest against principal amount deposited-Auction sale is nullified by court-Interest is capital receipt and cannot be assessed as income from other sources.[S. 56(2)(viii)]

S. 4 : Charge of income-tax-Capital or revenue Sales tax exemption-Notice is issued in SLP filed by the assesseee. [U.P. Trade Tax Act, 1948, S. 4A, Art. 136]

S. 2(22)(e) : Deemed dividend-Trade advances-Commercial transactions-Cannot be assessed as deemed dividend-Order of High Court is affirmed-SLP of Revenue is dismissed. [Art. 136]

S. 69C: Unexplained expenditure -Bogus purchases -Tribunal confirmed 10% of alleged bogus purchases – On appeal High Court deleted the 10% of alleged bogus purchases confirmed by the Tribunal . [ S. 260A ]

S. 115BBC : Anonymous donations – Determination of tax in certain cases – Charitable Trust – Anonymous donations received in the Hundi cannot be taxed under Section 115BBC(1) of the Act – Order of Tribunal is affirmed – No substantial question of law . [ S. 10(23C)(v), 11, 12 ,12A , 80G (5), 115BBC(2)(b), 260A ]