S. 10A : Free trade zone – If the assessee suo motu makes the adjustment and offers higher income, S. 10A/10B deduction cannot be denied. Also, as such notional income is not “export turnover”, the condition in s. 10A/10B that foreign exchange must be brought to India does not apply [ S. 10B, 92CA]

S. 10A : Free trade zone – Communication charges to be excluded from export turnover as well as from total turnover.

S.10A: Free trade zone – Eligible for set off unabsorbed depreciation . [ S. 32 ]

S. 10A : Free trade zone – Export amount was not received with in specified time denial of exemption was held to be justified .[ S.260A ]

S. 10 (23C): Educational institutions- Any income- Addition made as cash credits would also qualify the exemption . [ S.68, 115BBC ]

S. 10 (23C):Educational institution-Application for exemption was made before wrong authority- Authority concerned should have forwarded to the correct authority instead of rejecting the said application after enquiries . [ S. 10(23C) (iv) ]

S. 10(10B) : Compensation – Workman – De facto termination of employment on payment of agreed compensation — Eligible for exemption –Quantum to be examined by the AO .

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services –Payments made towards allocation of expenses cannot be treated as fees for technical services – DTAA-India – France [ Art . 13 ]

DCIT v. KPMG Advisory Services (P.) Ltd. (2018) 168 ITD 34 (Mum) (Trib

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Payment of SAP charges made to Associated enterprise for use of licensed software was liable to tax as royalty in India and liable to deduct tax at source- DTAA-India -Germany [S. 195, 201(1), 201(IA), Art 12 ].

S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – Professional charges paid by assessee to a non-resident company located in Bangladesh could not be brought to tax in India as royalty – DTAA- India – Bangladesh [ Art 13(2) ]