S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Payment made for use of software-Does not give rise to royalty-not table in hands of assessee-DTAA-India-USA. [Art. 12]

S. 281 : Certain transfers to be void -Natural justice – Order passed without giving an opportunity of hearing – Bad in law -Tax recovery Officer has no jurisdiction to examine whether the transfer is void-Order was quashed . [S. 222, Rule 11 of the Second Schedule, Art , 226, Transfer of Property Act , 1882, S.53 ]

S. 271B : Penalty-Failure to get accounts audited-Co-Operative Society-Receipt of Grant-In-Aid from Government of Maharashtra at predetermined rates on which tax deducted at source-Accounts audited under Co-Operative Societies Act-If amount of grant-in-aid excluded, turnover below limit specified-Reasonable cause for not getting accounts audited-Levy of penalty is not valid. [S. 44AB, 273B]

S. 271(1)(c) : Penalty-Concealment-Co-Operative Society-Interest income from Nationalised Banks incorporated in financial statements-Shown as income from other sources-Levy of penalty is not valid. [S. 80P(2)(a)(i)]

S. 271(1)(c) : Penalty-Concealment-Co-Operative Bank Disallowance of claim-Levy of penalty is not valid. [S. 36(1)(viia)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Purchases from Special Economic Zone unit claimed as deemed import-Value added tax input on deemed import as expense in Profit and Loss Account-Order passed by Assessing Officer erroneous-Revision valid. [S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Purchases from Special Economic Zone unit claimed as deemed import-Value added tax input on deemed import as expense in Profit and Loss Account-Order passed by Assessing Officer erroneous-Revision valid. [S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Failure to examine expenditure incurred with reference to dividend income-Revision is held to be valid. [S. 14A, 8D(2)(iii)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Share premium-Report of expert-PCIT is not entitled to reject valuation report in absence of report from another expert. [S. 56(2)(vii)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Capital gains-Capital asset-Relinquishment of right in asset-Compensation-Right to sue-Compensation correctly assessed as capital gains-Revision to assess the compensation as income from other sources is held to be not valid. [S. 2(14), 45, 56]