S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Consideration for resale / use of computer software-Payment is not payment of royalty-Not taxable in India-Not liable to deduct tax at source-DTAA-India-USA. [S. 195, 201(1), 201(IA), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Business of transmitting telecommunication signals to/from its customers-Income earned was not in nature of royalties-Not liable to tax in India-DTAA-India-USA. [Art. 12(3)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Support service-Outsourcing of work to India would not give rise to a fixed place PE-DTAA-India-Mauritius. [Art. 5]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Shipping business-Indian company an agent of independent status-Cannot be assessed as Agency PE of the assessee-DTAA-India-Mauritius. [Art. 5(5)]

S. 245 : Refund- Set off of refunds against tax remaining payable -Adjustment made without prior intimation is held to be bad in law .[ Art , 226 ]

S. 80IB(10) : Housing projects- Two flats excess of the prescribed limit of 1500 sq.ft – Pro rata deduction in respect of eligible flats not exceeding prescribed limit is eligible – Interpretation of taxing Statutes – When the language of a statute is unambiguous and admits of only one meaning, no question of construction of a statute then arises .[ S. 260A ]

S. 69C : Unexplained expenditure –Income from undisclosed sources – Bogus purchases -Civil works – Road construction -Information from Sales Tax Department – Order of Tribunal estimated profit of 12.5% on unexplained and non -genuine purchases is affirmed by High Court .[ S. 37(1), 143(3), 260A]

S. 36(1)(vii) :Bad debt – Pendency of dispute – Lease rental – Depreciation -Once a business decision has taken to write off a debt as a bad debt in books of account should sufficient to allow the claim as bad debt [ S. 36(2) ]

S. 68 : Cash credits –lenders are assessed to tax- Confirmation was filed – Interest was paid ,TDS was deducted – Notice issued u/s 133(6) were acknowledged – Order of Tribunal deletion of addition was affirmed – Court observed that the Assessing officer should have desisted from using the general observation and expression “money Laundering” when it was never the case that there was any allegations of money laundering . [ S. 133(6) ]

S. 276CC : Offences and prosecutions-Failure to furnish return of income-Assessee must be given opportunity to compound offence. [S. 139, 279, Art, 226]