S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Loan provided to Indian parties-Not attributable to the permanent establishment-Interest income taxable at 10 per cent and not 40 per cent. [S. 9(1)(i), 154, Art. 7, 11(6), 14]

S. 9(1)(v) : Income deemed to accrue or arise in India-Interest-Rate of tax-Government securities-Interest income received on rupee-denominated bonds-Rate applicable at the rate of 5 per cent or 15 per cent-Matter remanded-Offshore distribution commission income-No permanent establishment-Commission is not taxable in India. [S. 9(1)(i), 115AD, Art. 7, 11]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Engineering services to its Indian subsidiary-Absence of PE-Receipt is not taxable-DTAA-India-Thailand. [Art. 7, 12, 22]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Dependent agent (DAPE)-Remuneration at arm’s length-Tax neutral-Addition was deleted-DTAA-India-USA. [Art. 5, 7]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Capital gains-Share transactions-Beneficial ownership-AO is directed to decide the issue by passing speaking order-DTAA-India-Mauritius. [Art. 13]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Annual Maintenance Contract with an Indian Co-Not to constitute either a fixed place PE or agency PE business profit of assessee could not be taxed in India-DTAA-India-Singapore. [Art. 5, 8]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent establishment-Agency PE-Agent is paid arm’s length remuneration-Tax neutral-Not taxable-DTAA-India-Singapore. [Art. 5]

S.2(14)(iii): Capital asset-Agricultural land-Failure to provide evidence-Matter remanded back to Assessing Officer for verification [S. 10(37), 45]

S. 2(14)(iii) : Capital asset-Agricultural land-Hazira Notified area-not a municipal area or deemed municipality-Compensation received on the acquisition of such land was not taxable. [S. 10(37)]

S. 260A: Appeal -High Court – Territorial jurisdiction – Order passed by the Delhi Tribunal – Appeal filed in Calcutta High Court – Assessment files transferred from Delhi to Calcutta – Calcutta High Court has no jurisdiction- Appeals are rejected as not maintainable -Liberty granted to file the appeals before the appropriate High Court. [ S. 127, 254(1), 256(1), 256(2), 269 ]