S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Non-Resident-Income from sale of software licences-Not royalty-Not fees for technical services-DTAA-India-Singapore. [Art. 12(3)(a), 12(4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Non-resident-Fees for technical services-Hotel management support services-Services of business strategy, marketing and sales cannot result in fees for technical services-No Permanent Establishment in India-Not royalty-Additions are deleted-DTAA-India-Singapore. [S. 9(1)(i),9(1)(vi), art. 12(3)(a), 12 (4)(a)]

S. 4 : Charge of income-tax-Principle of mutuality-Association formed to promote machine tool industry-Holding exhibitions for both members and non-members-Matter is remanded. [S.11]

S. 271C: Penalty-Failure to deduct at source-Commission or discount allowed to dealers-Debatable and pending adjudication before Supreme Court-One of two possible views-Bona fide and genuine-Reasonable cause-Penalty is not justified . [ S. 194H , 201, 201(IA) , 273B ]

S. 271(1)(c): Penalty-Concealment-Bogus purchases-Loss assessed as positive income-Penalty is confirmed. [Explanation 4]

S. 271(1)(c): Penalty-Concealment-Notice stereotyped and irrelevant portion not struck off-Levy of penalty is not valid. [S. 274]

S. 263: Commissioner-Revision of orders prejudicial to revenue-
Revision-Deposit of cash-Demonetisation Period-Deposits directly made by debtors of assessee-Details of cash deposits from parties furnished before Assessing Officer-The Assessing Officer is an investigating and an adjudicating officer-It is not necessary to give a detailed reason in the assessment order in respect of each and every question for the completion of assessment-Possible view-Revision is not valid . [ S. 68, 143(3) ]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-
Revision-Provision for non-performing assets-write back-Corporate social responsibility expenses-Suo motu adding back expenses in revised return and offering it to tax-Additional Depreciation-Claim made in original return-Withdrawn in revised return-Revision order is quashed . [ S. 32, 37(1 139(5)143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Proper enquiry conducted in the original assessment proceedings-Possible view-Revision order is quashed-Delay of 963 days is condoned. [ S. 143(3) , 253(5) ]

S. 254(2A) : Appellate Tribunal-Stay-Long-term capital gains-Credit for taxes paid in Mauritius-Prima facie assessee entitled to stay-Directed to pay 20 percent of outstanding demand-Recovery proceedings stayed .