“Section 95(1)”

Revenue must demonstrate the existence of a Permanent Establishment (PE) of a foreign enterprise in India, including establishing that transactions underlying a Dependent Agent PE were not at arm's length. Income from the sale of goods is not taxable in India if title and risk in the goods pass outside India.

Exemption provisions and notifications must be interpreted strictly, and the burden of proving applicability lies with the assessee. If there is an ambiguity in an exemption clause, its benefit cannot be claimed by the assessee and must be interpreted in favour of the Revenue.

Reimbursement of expenses does not constitute income and is therefore not taxable as a revenue receipt. Such receipts are treated as a reduction of cost rather than income.

Non-response to Section 133(6) notices or the assessee's inability to compel third parties to reply cannot be the sole or sufficient ground for rejecting books of account under Section 145(3).

A notice is presumed to have been properly served if it is not returned as unserved, and objections regarding non-service are not acceptable in such cases.

Payments for the use of or the right to use copyright are covered by Section 9(1)(vi) of the Income-tax Act, 1961, and are to be considered as income accruing or arising in India.

Expenses incurred outside India for promotional activities benefit the entire trade in India, thus satisfying the requirement for application of income for charitable purposes within India, even if the expenditure occurs abroad.

The Income Tax Appellate Tribunal (ITAT) confirmed a decision regarding the eligibility for deduction under Section 80-IA of the Income Tax Act, 1961. The High Court formulated a question of law concerning whether the assessee fulfilled the conditions for this deduction.