Section 14 of the Income Tax Act

A statute should not be construed to permit double deduction for the same expenditure unless specifically provided by law.

A valid Tax Residency Certificate (TRC) serves as conclusive proof of an assessee's residency for the purpose of availing treaty benefits, unless specific instances of fraud or treaty shopping are proven by the revenue authorities.

Once a resolution plan is approved by the NCLT under Section 31(1) of the IBC, all claims, including statutory dues owed to the Central or State Government, are frozen and become binding on all stakeholders. This extinguishes any prior tax demands, such as those under Section 178(6) of the Income Tax Act, if not part of the approved plan.

Rental income from immovable property owned by an assessee must be assessed under the head 'Income from House Property' (Section 22), even if the assessee is engaged in the business of real estate or property development and leasing. This emphasizes the mandatory classification of income under its specific statutory head.

When a statute mandates a specific procedure for an act and imposes severe consequences for non-compliance, that requirement is mandatory and must be strictly followed. This principle underscores the strict construction of taxing statutes, requiring compliance in the prescribed manner and no other way.

A receipt not chargeable as capital gains under Section 45 cannot be taxed under the residuary head of income from other sources (Section 56). If a receipt is not taxable under specific provisions, it cannot be brought to tax under any other section.

A charitable trust can claim depreciation on assets when computing the income applied for charitable or religious purposes under Section 11 of the Income Tax Act, for assessment years prior to the introduction of Section 11(6). The restriction on claiming depreciation, as introduced by Section 11(6), is prospective from AY 2015-16.

The heads of income specified in the Income Tax Act are mutually exclusive, requiring any item of income to be charged and computed solely under its specific statutory head, with Section 56 (Income from Other Sources) serving as a residuary provision.

A subsequent amendment cannot impose a new tax burden or liability for a period when such liability did not exist. Therefore, additional tax or penalty cannot be levied for non-disclosure of income made taxable retrospectively by an amendment not in force at the time of the original return.

The case distinguishes between the transfer of copyright and the mere right to use copyrighted material, holding that payments for the supply or use of computer software generally constitute business income, not royalty, under Double Taxation Avoidance Agreements (DTAAs), and are not taxable in India without a Permanent Establishment.