S. 9(1)(vi): Income deemed to accrue or arise in India-Royalty-Screening and investigation services to its customers in India-Not royalty-Addition was deleted-India-UK. [Art. 5, 13]

S. 9(1)(v): Income deemed to accrue or arise in India-Interest-advanced External Commercial Borrowing (ECB)-Assessee could claim set-off of current year business loss of PE against interest income earned from Indian customers on ECB loans-Treaty itself provided for taxability of income in terms with domestic law provisions-Interest income would be covered under section 115A(1)(a)(iiaa), hence, subject to concessional rate of tax at 5 per cent with applicable cess and surcharge-DTAA-India-UAE [S. 9(1)(i),115A, Art. 11]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Service fee-Service agreement of infrastructure services, Web EDI system maintenance agreement, etc.-DRP should revisit the issue upon examining documents which were not placed before it-Matter remanded-DTAA-India-Thailand.[Art. 7, 22]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Capital gains-Shares/Units-Pass through entity-TRC-Entitled to benefits of DTAA-India-Cyprus.[S. 45, Art. 13]

S.2(14)(iii): Capital asset-Agricultural land-Beyond 8 kms from municipal limits of Gurgaon and filed certificate from Nayab Tehsildar-Land could not be treated as a capital asset under section 2(14)-Accepted in co-owner-Not assessable as capital gains. [S. 2(14), 45]

S. 2(14)(iii) : Capital asset-Capital gains-Agricultural land-16 kms from municipality-Cultivation of groundnut-certificate from Village Administrative Officer-Exempt from taxation. [S. 45]

S. 281B: Provisional attachment-Additions were set aside-Entire arrears were paid-The tax recovery officer was directed to release attached property.[S. 153A, 153C, 225, 226, Art. 226]

S. 220: Collection and recovery-Assessee deemed in default-No wilful disobedience of earlier court order-Contempt proceedings were dropped. [Contempt of Courts Act, 1971, S. 2(b)]

S. 153A : Assessment-Search or requisition-Unabated assessment-No incriminating material found-Order of Tribunal deleting the addition was affirmed. [S. 260A]

S. 151A: Faceless assessment scheme-Reassessment proceedings were initiated by the jurisdictional Assessing Officer-Reassessment notice and consequential proceedings were quashed. [S. 148, 148A(b) 148A(d), Art. 226]