S. 12A : Registration –Trust or institution-Deemed Registration us 12A due to non-disposal by the Revenue-Matter remanded. [S.11]

S. 11 : Property held for charitable purpose-Anonymous donations-The donations given by the donors whose addresses were not furnished to Assessing Officer, would fall within the ambit of section 115BBC and the donations given by donors whose addresses were duly furnished to the Assessing Officer, would be eligible for exemption under section 11(1)(d).[S. 2(24)(iia),11(1)(d), 115BBC,131, 133(6)]

S. 11 : Property held for charitable purposes-Exemption not claimed as ITR-5 was filed instead of ITR-7-Partnership firm-Order of adjustment is justified. [S. 143(1),154 184]

S. 11 : Property held for charitable purpose-Registration-Corpus Donations-Registration condition precedent for exemption in respect of corpus donations-Cash credits-Genuineness of loan is doubtful-Addition is proper-Business expenditure-Each item of expense considered and disallowance restricted to expenses not verifiable-No Justification for further reducing disallowance. [S.12AA, 68]

S. 10(23C) : Educational Institution-Rejection of application seeking approval u/s 10(23C)(vi) of the Act by the CIT (Exemption) merely stating that the Trust did not exist solely for educational purpose-Entitle to approval. [S.10(23C)(vi)]

S. 10(23C): Educational institution-Provisional approval granted u/s 10(23C) is not equivalent to the grant of registration for the purpose of S. 11(7) [S. 10(23C(vi) 11(7), 12A]

S. 10 (23C): Educational institution-Bogus donation-Donation supported by certificate of recognition of Director General of exemptions and bank statements-Denial of exemption is not proper-Retracted statements not incriminating material-Cannot be used to reopen concluded assessment-Gratuity-Leave encashment-Provision for gratuity or leave encashment-Constitutes ascertained liability-Allowable as deduction. [S. 12AA, 80G, 143(3) 153A]

S. 9(1)(v) : Income deemed to accrue or arise in India -No permanent establishment- Interest paid by the Indian branch/PE to the head office/GE is not taxable in India- DTAA-India-France.[Art.7(3)]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services -Amounts received towards the provision of SAP & IT services on a recurring basis are not in the nature of FTS- Not taxable in India-DTAA-India -Israel [S.9(1)(i), Art. 13]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Permanent Establishment — Providing online decision support applications for Airline companies in India-Not business income — Taxable only on gross basis under Section 115A at 10 Per Cent. — Expenses not allowable —DTAA -India -USA.[S. 9(1)(i), 44DA,