S. 11 : Property held for charitable purposes-Application of income-Trust is allowed to carry forward deficits of earlier years and set it off against surplus of subsequent years-Accumulation of income-Amendment is applicable from 1-4-2022 and will, accordingly, apply in relation to assessment year 2022-23 and subsequent assessment years. [S. 10(23C)]

S. 10 (23C) : Educational institution-Deficiency in completeness of information sought-Matter remanded. [S. 10(23C)(vi)]

S. 10(13A) : House rent allowance-Loan to spouse-Purchase of house property in the name of wife-House rent paid to wife-Denial of exemption is not valid. [S. 64]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Granting access to its data base and user of data base-Not to be considered as royalty-Not liable to deduct tax at source-DTAA-India-USA. [Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Management support services to its Indian subsidiary-Master consultant sharing agreement to supply manpower-Miscellaneous services to third parties in India-Not taxable as FIS-DTAA-India-USA. [S. 9(1)(vi), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Information technology support services to its group entities-Matter remanded-DTAA-India-USA. [S. 9(1)(vii), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Supply of software embedded in hardware equipment-Not royalty-Addition was deleted-DTAA-India-France. [Art. 13]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Business of marketing advertisement time of different television channels-Secret formula or process-payment made for utilization of transponder centered on a satellite would not constitute royalty-Not liable to deduct tax at source-DTAA-India-USA-UK-Malaysia. [S. 195(2), Art. 12, 13]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Dependent Agency Permanent Agency-Indian subsidiary to distribute subscription supported television programming service to Indian subscribers-Distribution income cannot be taxed in India-Indian subsidiary was remunerated at ALP by assessee, no further profit/income could be said to be attributable to assessee for purpose of taxation in India-transponder fee and uplinking charges to US based company for providing facilities of telecasting channels of assessee in India-Not royalty-DTAA-India-Mauritius-India-USA. [S. 9(1)(vi), 195, Art. 5(4), 12]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Interest-Interest on income tax refund-Interest on income tax refund is not effectively connected with PE either on basis of asset-test or activity-test and, hence, it is taxable as per provisions in Para No. 2 of article XI of Indo-US DTAA-DTAA-India-USA [S. 9(1)(v), 90, Art. 11]