S. 11 : Property held for charitable purposes-Rent receipt-Receipt from rent by assessee-society was in course of actual carrying out of objects of general public utility and same was below 20 per cent of total receipt-Commissioner (Appeals) is justified in allowing benefit under sections 11 and 12-Corpus donation-Donation received by assessee-society were with specific direction and also utilized for construction of fixed assets i.e. bhawans only, same was corpus donation exempted under section 11(1)(d) [S.2(15), 11(1)(d), 12A]

S. 11 : Property held for charitable purposes-Promotion of education, culture and philosophy-Returned filed in wrong form-Filed return in Form 5 claiming loss which is meant for business income-The Assessing Officer is directed to consider return as a rectification petition. [S.12AA, 139(4A), 139(9), 139C, 143(1), 154, Form No 5, Form No 7,]

S. 11 : Property held for charitable purposes-Specified persons-Adequate consideration-Rental value adopted by Assessing Officer was less than 10 per cent rent received by assessee-Denial of exemption is not justified.[S.12, 12A(a), 13(2)(b), 13(3)]

S. 11 : Property held for charitable purposes-Activities for upliftment of poor, providing training and skill development to poor in rural areas-Denial of exemption is not justified.[S. 2(15)]

S. 11 : Property held for charitable purposes-Depreciation-Application of income-Application of income more than 85 percent of total income before depreciation-Matter remanded to the file of the Assessing Officer for deciding the issue accordance with law.[S.10(23C)(vi), 11(6),12A(a), 32]

S. 11 : Property held for charitable purposes-Profit motive-Business activity-Eligible to exemption-Depreciation-Allowable. [S.2(15), 12A, 13, 32]

S. 11 : Property held for charitable purposes-Form No 10B-Audit report-Delay of 28 days-COVID-19-Delay is condoned-Exemption is allowed. [S. 119, Form No 10B]

S. 11 : Property held for charitable purposes-Delay in filing Form No 10B-COVID-19-Delay is condoned.[S. 119, Form.No 10B, 10BBA]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Make available-Payments made to US company for administrative and IT services-Can not be treated to be in nature of FTS-Not liable to deduct tax at source-DTAA-India-USA [Art. 12(4)(b).]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Telecom and transmission services-Reimbursement from its Indian subsidiary for provision of connectivity services for international communication-Cannot be treated as fees for technical services-DTAA-India-Hong kong [Art. 12]