“Section 104(1)”

A delay in filing an appeal cannot be condoned if it is attributable to the assessee's negligence or inaction, such as misplacing and forgetting the Commissioner (Appeals)'s order. The provisions relating to limitation apply with rigour, and a lack of due care and attention is not a sufficient reason for condonation.

The annual value of a self-occupied property, for both wealth tax and income tax purposes, is the reasonable rent expected from a hypothetical tenant. When using municipal ratable value, statutory deductions permissible under municipal law must be added back to arrive at this expected rent.

Software installed in India granting access to an assessee's mainframe located outside India does not constitute a Permanent Establishment (PE) in India. Agents are not considered to have an agency PE if they are not economically dependent on the assessee and lack the authority to conclude contracts.

The Appellate Assistant Commissioner (AAC) has the power to conduct further inquiries, permit fresh grounds of appeal, and raise new points during the disposal of an appeal, irrespective of Rule 46A.

Where an assessee's income is estimated under Section 145(3), no further additions can be made to the 'income from business' head, though income from other heads may be computed separately.

The Delhi High Court has held that services provided by payment gateways can be considered fees rather than commission, distinguishing them from brokerage paid for facilitating the buying or selling of goods.

No fee for delay in filing TDS return can be computed under Section 234E for assessment years prior to June 1, 2015.