S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Business of operation of ships in international traffic-Treaty must be extended to entire freight receipts, irrespective of whether earnings are relating to feeder vessels or by ships in international traffic-DTAA-India-UAE. [S. 90, Art. 8]

S. 4 : Charge of income-tax-Sales tax subsidy Capital or revenue-After commencement of commercial production-Quantum depends upon production and sales-Reimbursement of sales tax paid-Assessable as revenue receipt. [S. 28(i)]

S. 4 : Charge of income-tax-Diversion by overriding title-Under liquidation-Interest income-Interest income by assessee post liquidation was diverted at source by overriding title for payment of DICCI and not taxable as income of the assessee. [S. 145]

S. 4 : Charge of income-tax-Air craft-Credit given was not for incidental to business-Commission-Not chargeable to tax as revenue receipt-Receipt is capital in nature-credits received by assessee from engine manufacturer for selecting its engine in aircraft would not be taxable as business income. [S. 28(i), 28(iv), 43(1)]

S. 2(22)(e) : Deemed dividend-Loans and advances to share holders-Common share holder-Not share holder from which it had received loan-Additions cannot be made.

S. 263: Commissioner – Revision of orders prejudicial to revenue – AO examined the issue – PCIT cannot demonstrate the error or lack of enquiry – Cannot be deemed to be erroneous – S. 56 (2)(viia) not applicable to gifting of shares of a listed company. [ S. 56(2)(viia) ]

S. 148: Reassessment – Issuance of notice of reassessment – Resolution personal -Provisions of this Code to override other laws – For period prior to approval of resolution plan under the Insolvency & Bankruptcy Code, 2016 (‘IBC’) – Once the public announcement is made under the IBC by the Resolution Professional calling upon all concerned, including the statutory bodies, to raise claim, it would be expected from all the stakeholders to diligently raise their claim- Not maintainable against the Corporate Debtor- Notice issue was quashed (S. 147, The Insolvency and Bankruptcy Code , 2016 , S. 7, 30(2), 238, Art , 226 )

S. 281 : Certain transfers to be void-Transfer to defraud revenue-Mortgages-Pendency of recovery proceedings-Transaction or transfer became void-Doctrine of the priority of Crown debts-Disputed factors cannot be adjudicated by the High court in a writ petition. [S. 222, Schedule II Rule. 11, Recovery of Debts and Bankruptcy Act, 1983, S. 31B, Securitisation and Reconstruction of Financial Assets and Enforcement of Security Interest Act, 2002, S. 26E, Art. 226, 265, 268A]

S. 270AA : Immunity from imposition of penalty, etc-Application accepted the assessee cannot file an appeal or revision application-Application is rejected there is no bar-Matter remanded. [S. 246A, 264, 270AA(4), Art. 226 ]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-COVID-19-Violation of principle of natural justice-Order passed without giving an opportunity of hearing was set aside-Matter remanded. [Art. 226]