S. 10(20): Local authority-Change of law-For years prior to and subsequent to AY in question assessee treated as “local authority”-To be assessed as local authority for year in question-Not as artificial juridical person. [S. 2(31)(vii)]

S. 10(13A) : House rent allowance-Rent paid by husband to his wife-house was registered in wife’s name-Rental income was shown by wife in ITR-Deduction of house rent allowance is allowable as deduction.

S. 10(2A) : Share income of partner-The Limited Liability of Partnership,(LLP) being a distinct person from its partners can become a partner in a partnership firm and is also eligible to claim the exemption. [S. 2(23), Indian Partnership Act, 1932 ,S. 4,25,26,49, Limited Liability of Partnership ,Act, 2008,S.. 14,General Clauses Act, 1897, 3(42)]

S. 10(1) : Agricultural income —Business of manufacture and sale of sugar-Income from cultivation of sugarcane seeds treated in earlier years as agricultural income-Exempt from tax.

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Non-resident-Subscription fees receipt from India – Online Database-Not taxable in absence of permanent establishment in India-DTAA-India-USA .[S.9(1)(i), Art. 7]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services – Reimbursement of salaries paid to employees-Employees were high level technical executives-Payments fell under technical services-Tax deducted at source not relevant-Payment taxable. [Explanation. 2]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Granting access to database and earning subscription fee-Income not taxable in India-DTAA-India-USA. [Art. 12(3)]

. 237 : Refunds – Failure to issue refunds – Alleged “due to system issue “ – Negligence of the officers – Court directed the Officer to credit the amount of the refund to the account of the petitioner not later than 10.30a.m on 30 th April 2024 , along with accumulated interest under section 244A of the Act , up to 29 th April , 2024 .[ S. 244A , Art. 226 ]

S. 45: Capital gains – Consideration received for subsequent granting of development as per the commitment letter for granting permission to right for uploading TDR is assessable as long term capital gains and not as income from other sources – Substantial question of law raised first time before the Honourable High in an appeal filed by the assessee is admitted by the Honourable High Court . [ S. 56 , 260A ]

S. 9(1)(v) : Income deemed to accrue or arise in India – Interest-Bank is a subsidiary of Netherlands company — Interest paid by Indian branch not taxable in hands of head office or overseas branches — Change of law with effect from 1-4-2016 not be applicable prior to ay 2016-17-DTAA-India-Netherlands [Art. 11(2)]