S. 250 : Appeal-Commissioner (Appeals ) -Procedure -Faceless Appeal Scheme – Video Conference -Natural justice – Opportunity for personal hearing not granted – Retrospective effect- Order set aside and remanded back. [ S. 250(6B) , National Faceless Appeals Scheme 2020, Rule 12(2), 12(3), 13(2) ]

S. 9(1)(i): Income deemed to accrue or arise in India – Permanent establishment – Interest will not be taxed at a higher rate- DTAA- India- Japan . [ Art, 7, 11(2)(11(6), 14 ]

S. 90: Double taxation relief – Foreign Company – discrimination allowed – Company has not made prescribed arrangement-DTAA-India -Korea . [ S. 2(22A), Art, 25(1)]

S. 144C: Reference to dispute resolution panel – Rectification application by TPO – Rectification order by DRP – Not maintainable. [ S. 144C(14), 154 ]

S. 260A : Appeal – High Court -Delay in disposal of appeals – Change in Panel counsels – CIT(judicial) to make necessary arrangements in two weeks.

S. 10(1) : Assessment-Notice under section 10(1) jurisdictionally defective and violative of the principles of natural justice on account of simultaneous proceedings under the Black Money (Undisclosed Foreign Income and Assets) and Imposition of Tax Act, 2015 and Income-Tax Act, 1961-Order was quashed. [S. 2(11). 4(3), 14, 59].

S. 17 : Wealth tax escaping assessment-Non-supply of reasons-Off-shore irrevocable discretionary trusts-Reassessment proceedings null and void owing to non-supply to the assessee of the reasons recorded-Off shore trust assets including immovable property in Singapore and London were not vested in the assessee and such assets held through offshore corporate vehicles are exigible only in the hands of such vehicles and not in the hands of the assessee-Deposits in offshore banks do not constitute an asset and hence are excluded from chargeability to tax under Wealth-tax Act-ITSC commission order is not binding on wealth tax proceedings. [S. 2(ea), 2(m)]

S. 7 : Valuation of asset-Asset sold 28 days after valuation date-Value determined at guideline value on date of sale is not proper-Valuation to be at market value on valuation date-Dispute as to extent of landholding-Matter remanded. [S. 7(1),

S. 5(i): Exemption-Asset-Urban land-Property held under trust-Land leased to educational institution-Building constructed-Lands cannot be held to be vacant lands-Not liable to wealth-tax. [S. 2(ea)(v), IT Act, S. 11, 13(1)(c)]

S. 2(e)(a) : Assets-Vacant Urban land-Not vacant land-Existing building was demolished-Semi finished building-Matter remanded for re verification.