Section 163 of the Income Tax Act

This case established a principle regarding the application of Double Taxation Avoidance Agreements (DTAAs) versus domestic tax law, particularly concerning the use of more beneficial provisions for an assessee, though its specific impact has been nullified by subsequent legal amendments.

Rules and notifications issued under fiscal statutes apply prospectively unless expressly stated otherwise. This principle was affirmed in the context of disallowance under Section 14A of the Income Tax Act.

Tax treaties are considered self-contained mini legislation that encompass all relevant aspects, and these features may differ from the general taxation laws of the respective countries.

An assessment under Section 153A cannot be made for additions to income relating to deposits in a foreign bank if the assessment for that year was already completed under Section 143(3) and no incriminating material was found during the search.

A Double Taxation Avoidance Agreement can restrict the Indian government's power to tax income by implication, even affecting Sections 4 and 5 of the Income Tax Act, 1961.

Income arising to an Indian resident from a foreign country is not taxable in India if the applicable Double Taxation Avoidance Agreement (DTAA) provides for taxation only in that foreign country. Even an Indian resident can avail benefits under a DTAA.

Branches of a company in foreign countries such as UAE and Qatar do not attract tax liability in India when they form a Permanent Establishment (PE), provided that the relevant tax treaties are applied. This principle has been upheld by the Supreme Court.