S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of online advertisement space to GIPL, India and to direct advertisers-Payment received from GIPL is not in nature of royalty or FTS-Not liable to tax in India-DTAA-India-Ireland.[S.9(1)(vii), Art. 12]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Limited Liability Company (LLC)-Resident of USA State by virtue of US Income-tax Law-Qualified as a person under Article 4 of Indo-US Tax Treaty-Eligible for treaty benefit-Liable to tax at 15 % and not 25%-DTAA-India-USA [S.90, Art.4, 12]

S. 6(1) : Residence in India-Individual-Indian citizen-Stayed in India more than 183 days-Income derived in USA is chargeable to tax in India-DTAA-India-USA [S. 5, 9(1)(i),Art. 4(2)(a)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Excess provision of Corporate Social Responsibility expenses of earlier years should have been first written back to profit and loss account and not in Balance-Sheet-No discussion in the assessment order-Revision is justified. [S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Business expenditure-Four projects-Apportionment of expenditure to projects-Order of CIT is affirmed-The Principal Commissioner is required to provide reasonable opportunities of being heard to the assessee before deciding the case on the merits. [S.37(1)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny to full scrutiny-No mention in order-sheet that limited scrutiny converted into full scrutiny-Neither Principal Commissioner nor Department producing any document or approval for converting limited scrutiny into full scrutiny in case of assessee-Revision order and consequential proceedings bad in law-No appeal is filed against 263 order-Revision jurisdiction in this case by the Principal Commissioner was wrong and illegal, the consequential order passed under section 143(3) of the Act was also not sustainable in the eyes of law and was accordingly quashed. [S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Contribution to core settlement guarantee fund controlled by Indian Clearing Corporation-Details filed before the Assessing Officer-Failure to showing how order of Assessing Officer is prejudicial to Revenue-Revision order is set aside. [S.10(23EE), 143(3)]

S. 253 : Appellate Tribunal-Appeals-Delay of 506 days-Sufficient cause-Not diligent in pursuing issue relating to application-Delay is not condoned. [S.12A, 253(5)]

S. 250 : Appeal-Commissioner (Appeals)-Procedure-Grounds of appeal-Deciding altogether different grounds of appeal which were not there in memorandum of appeal in Form 35 and allowing Appeal of assessee-Order set aside and direction to Commissioner (Appeals) to look into facts and pass an order on merits after giving proper opportunity of hearing. [S.68, 133(6), 246A, Form No. 35]

S. 154 : Rectification of mistake-Mistake apparent from the record-Depreciation-Additional depreciation-Additional claim-Mismatch to be looked into and rectified after verification-Matter remanded. [S. 32, 143(1)]