S. 11 : Property held for charitable purposes-Imparting first aid training to students, schools, companies and institutions etc-Advancement of any other object of public utility-Charitable activity-Matter remanded to the AO. [S. 2(15), 12]
S. 11 : Property held for charitable purposes-Imparting first aid training to students, schools, companies and institutions etc-Advancement of any other object of public utility-Charitable activity-Matter remanded to the AO. [S. 2(15), 12]
S. 11 : Property held for charitable purposes-Non-filing of Form 10B-Directory-Exemption cannot be denied. [S. 143(1), Form No 10B]
S. 10A : Free trade zone-Form signed by Deloitte Haskins and Sells-Form 56F was not signed by an Accountant, as referred in sub-section (5) to section 10A-Defective form-Not entitle to deduction.[S. 10A(5), 10AA, 44AB, 288(2), Form 56F, Chartered Accountant Act, 1949, 2(1), 6(1)]
S. 10(34A) : Share holder-Buy back of shares-No difference in value-No liability under section 11QA-Not colorable device-Eligible for exemption. [S.115QA]
S. 10(23C) : Educational institution-Objectional clause-Not carried out any activities as per objectional clauses-Exemption cannot be denied-Modified the objectionable objects-Matter remanded to Commissioner (E). [S.10(23C)(iv), Companies Act, S.8]
S. 10(23C) : Educational institution-Grants-Interest from fixed deposits-Interest received on fixed deposits made out of unspent grants would be treated as a grant and if said interest amount was added to total grants received during year-Excess of 50 per cent-Entitle to exemption.[S. 10(23C)(iiiac)]
S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Cost Contribution Agreement (CCA) with group company, incorporated in UK, for provision of Business Support Services (BSS)-Services were in nature of managerial services and not technical services-Not taxable as fee for technical services (FTS)-The amount received by assessee, a UK based company, towards usage charges of software was not payment of royalty for use of copyright in computer software, and same did not give rise to any income taxable in India-DTAA-India-UK [S. 9(1)(vi), Art. 13]
S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Make available-Provided/sublicensed software to entities in financial service sector and also provided maintenance, support and training services and received fees towards same-No PE in India-Recipient, fees received by assessee could not be taxed in India-Additional services related to implementation and migration of software to its Indian customers-Business receipts-No PE in India-Not taxable-DTAA-India-Singapore. [S.9(1)(i), Art. 12 (4)(b)]
S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Supply of drawings and designs-Not assessable as fees for technical services-Supervisory services-Contract competition method-Remanded to the Assessing Officer-DTAA-India-Germany. [S. 9(1)(vi, 147, Art. 7, 12]
S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Fees for provisions for other related services-Software itself is not taxable-Addition made for other related services is deleted-DTAA-India-UK.[S. 9(1)(vi), Art. 13]