S. 4 : Charge of income-tax-Capital receipt-Government subsidy-Subsidy received for capital purposes is not taxable as a revenue receipt. [S.28(i)]

S. 271(1)(c): Penalty-Concealment-Furnishing inaccurate particulars of income-Penalty based on disallowance of payment treated as Fees for Technical Services-Quantum addition deleted-Penalty deleted.

S. 263: Commissioner-Revision of orders prejudicial to revenue-Reassessment-Scope of revision confined to issues arising from reassessment-Commissioner cannot direct enquiry into matters outside reasons recorded for reopening. [S. 147, 148]

S. 254(1): Appellate Tribunal-Powers-Additional grounds-Pure question of law arising from record-Additional grounds admissible.

S. 254(1) : Appellate Tribunal-Powers-Additional ground-Pure question of law requiring no fresh investigation of facts-Admitted.[S.10AA, 139]

S. 234B: : Interest-Advance tax-Levy of interest-Mandatory and consequential.[S. 234C]

S. 199: Deduction at source-Credit for tax deducted-Return held non est-Assessment-Assessing Officer bound to grant credit of taxes and consequential refund.[S.139(9),143(3), 237]

S. 195: Deduction at source-Non-resident-Other sums-Fees for Included Services-Pre-clinical laboratory services-No “make available” of technical knowledge-Receipts not taxable in India-No obligation to deduct tax at source-DTAA-India-USA.[S.9(1)(vii), 90(2) Art. 12]

S. 194C: Deduction of tax at source-Contractors-Common Area Maintenance (CAM) charges-Charges paid to independent service providers-Not part of rent-Tax deductible under section 194C at 2 per cent and not under section 194-I. [S. 194-I, 201(1), 201(1A)]

S. 153A: Assessment-Search and seizure-No incriminating material-Difference between physical stock and book stock by itself cannot constitute incriminating material-Addition based only on sworn statement without corroborative evidence-Assessment quashed-Delay of three days was condoned.[S. 37, 132, 143(3), 253]