S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Threshold period of twelve months for activities in India not exceeded-Not taxable in India-DTAA-India-Cyprus.[Art. 5(2)(g), 7]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Fees for technical services-Indian company merely displaying and storing data of Indian subscribers-Services limited to provision of E-Commerce platform of advertising of products of services in India-Standard facility-Not fees for technical services-Not taxable in India-DTAA-India-Singapore [S.9(1)(vii), Art.]

S. 4 : Charge of income-tax-Accrual of income-Interest-Interest credited to interest suspense account-Taxed in earlier year-Written off in the relevant year-Order of Tribunal is affirmed. [S. 145, 260A]

S. 153C : Assessment – Income of any other person – Search – Block period – The period of the “relevant assessment year” is to be calculated, to the date of receipt of the books of accounts, documents or assets seized by the jurisdictional AO of the non-searched person- Block periods would have to be reckoned with reference to the date of search can neither be countenanced nor accepted- Precondition of Rs. 50 lakhs or more constitutes a sine qua non for initiating action for the extended ten-year block, the aforesaid satisfaction and the reasons in support thereof would have to borne out from the satisfaction note itself. [ S.68, 69C, 153A, 260A, Art. 226 ]

S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Non-resident of Indian –Jurisdiction to be checked at the time of issue of notice – The Honourable Curt also observed that the Assessing Officer has taken dishonest stand -Notice and consequential order passed by the Assessing Officer for the relevant year is quashed -. [S. 120 , 148 ,148A(b),m148A(d) Art . 226 ]

S. 271C : Penalty-Failure to deduct at source-Interest payable to Uttarakhand Environment Protection and Pollution Control Board on FDs with the assessee-Board not a taxable entity, established under Central Act-Penalty not leviable. [S.194A(3), Notification No. S. O. 3489(E), Dated 22-10-1970.]

S. 271C : Penalty-Failure to deduct at source-International transaction-Arm’s Length Price-Concealment of income or furnishing inaccurate particulars-Penalty levied on enhancement of Transfer Pricing adjustments-Tribunal directing inclusion or exclusion of certain comparables-If Directions Of Tribunal Given Effect By Assessing Officer Basis Transfer Pricing Adjustments Would Not Survive-No Question Of Penalty. [S. 92C, 92CA (3)]

S. 271AAB : Penalty-Search initiated on or after 1st day of July 2012-Statement on oath-Undisclosed Income-Conditions-Admission in statement recorded during search not the sole criteria-A.O. not recording satisfaction-No legal basis for sustaining charge of undisclosed income-No basis for levy of penalty. [S. 132, 132(4)]

S. 271AAB : Penalty-Search initiated on or after Ist day of July 2012-Assessee declared income including income surrendered during search-A.O. initiating penalty-Show cause notice unclear with respect to which clause-Cash available with assessee as consequence of savings and gift-Cannot be treated as undisclosed income-Penalty quashed.[S. 132, 132(4), 274]