S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent Establishment-Fees for technical services Tax resident of China-Indian subsidiary concluding contracts on behalf of assessee-Active involvement-Income attributable is taxable in India-Royalty-Income from software embedded in hardware equipment supplied to customers in India-Does not amount to royalty-Not taxable in India-DTAA-India-China [S. 5(2), 9(1)(i), Expln 2,9(1)(vi) Art.12]

S. 271B : Penalty-Failure to get accounts audited-Business of imparting tuition classes-Income is estimated-levy of penalty is affirmed. [S.44AA, 44AB 271A, 271AB]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Deemed to accrue or arise in India-Royalties/fees for technical services-Off-shore sales-Order is passed after detailed enquiry-Revision is quashed-DTAA-India-Singapore. [S. 9(1)(vii), 143(3) Art. 12]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny-Purchase of residential property was entered by parties in AY 2008-09 even for consideration lower than market price, provisions of section 56(2)(vii)(b) would not be applicable as it came into existence from 1-10-2009-Revision order is quashed.[S. 56(2)(vii)(b)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Income from other sources-Expenditure claimed-Allowability of interest-Verified in the course of original assessment proceedings-Revision order is quashed.[S.36(1)(iii), 56, 57]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Method of accounting-Income Computation and Disclosure Standards (ICDS)-Accrual-NBFC Governed by RBI was not required to recognize its accrued interest on NPAs as income on accrual basis, provisions of ICDS would not be applicable

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains-Transfer of land used for agricultural purposes-Accepted the claim in another co-owner-Order is passed after [S. 54B]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Cash deposited-Demonetization period-Assessing Officer has added 20 percent of sales as unexplained cash credits-Revision order is quashed. [S. 68]

S. 253 : Appellate Tribunal-Appeals-Impleaded as corporate debtor before NCLT by financial creditor-Petition is admitted-Pending proceedings before ITAT cannot be continued-Provisions of IBC would prevail over Income-tax Act.[S. 254(1), Insolvency and Bankruptcy Code, 2016, S. 4, 31, 238]

S. 253 : Appellate Tribunal-Appeals-Impleaded as corporate debtor before NCLT by financial creditor-Provisions of IBC would prevail over Income-tax Act-Appeal is not maintainable. [S. 254(1), Insolvency and Bankruptcy Code, 2016, S.14, 31, 238]