S. 11 : Property held for charitable purposes-Object of general public utility-Serve as forum for exchange of ideas in mobility engineering and creation, maintenance and adherence of code of conduct for profession-Conducting meetings, workshops, seminars and other educational programs for development of mobility engineering-Falls under “Any Other Object of General Public Utility”-Objects and activities in nature of trade, commerce or business-Entitlement to exemption to be examined in light of gross receipts and receipts from activity of trade, commerce or business-If gross receipts from conducting conferences considered, receipts exceeded 20 Per Cent. of gross receipts of assessee-Matter remanded-Mutuality-Matter remanded-Taxability of corpus donations receipts towards magazine fund and depreciation to be considered afresh in light of amended provisions of Section 2(15) and of Supreme Court In Asst. CIT (E) v. Ahmedabad Urban Development Authority [2022 449 ITR 1 (SC) [S. 2(15)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Sale and maintenance service of software licences-Not fees for technical services-Not taxable in India-DTAA-India-Singapore. [Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Commission for sale of books-Not fees for technical services-Not taxable in India-Royalty-Subscription fees for sale of online books and Journals-Not royalty-Not taxable in India-DTAA-India-Germany. [S.9(1)(vi) Art.12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Non-Resident-Income from sale of software licences-Not royalty-Not fees for technical services-DTAA-India-Singapore. [Art. 12(3)(a), 12(4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Non-resident-Fees for technical services-Hotel management support services-Services of business strategy, marketing and sales cannot result in fees for technical services-No Permanent Establishment in India-Not royalty-Additions are deleted-DTAA-India-Singapore. [S. 9(1)(i),9(1)(vi), art. 12(3)(a), 12 (4)(a)]

S. 4 : Charge of income-tax-Principle of mutuality-Association formed to promote machine tool industry-Holding exhibitions for both members and non-members-Matter is remanded. [S.11]

S. 271C: Penalty-Failure to deduct at source-Commission or discount allowed to dealers-Debatable and pending adjudication before Supreme Court-One of two possible views-Bona fide and genuine-Reasonable cause-Penalty is not justified . [ S. 194H , 201, 201(IA) , 273B ]

S. 271(1)(c): Penalty-Concealment-Bogus purchases-Loss assessed as positive income-Penalty is confirmed. [Explanation 4]

S. 271(1)(c): Penalty-Concealment-Notice stereotyped and irrelevant portion not struck off-Levy of penalty is not valid. [S. 274]