S. 11 : Property held for charitable purposes-Covid-19-Delay in filing return and Form No 10B-Supreme Court extending the period of limitation-Entitle to exemption. [S.12AA, Form No 10B]

S. 11 : Property held for charitable purposes-Object of general public utility-Business-Income from organising meetings, conferences and seminars, membership fee from members, interest on deposits and rentals from properties-Disseminate knowledge on specialised issues to members and non-members-Not business purposes-Subscription fee from existing members on annual basis as well as admission fee from new members is not income by virtue of principle of mutuality-Advancement of main object is not hit by proviso to Section 2(15) even post-amendments-Invested in terms of section-Entitled to exemption in respect of entire receipts-Depreciation-Directed to allow depreciation as application of income-Capital Gains-Sale of old motor car and purchase of new car-No opening written down value for year-Even if entire cost claimed as application of income, assessee is entitled to claim deduction of written down value from sale consideration for calculating capital gain-Accumulation of income-Accumulation is to be computed on gross receipts and not net receipts [S. 2(13), 2(15), 10(23C),(11(1)(a), 11(2), 11(5)(iii),12A, 13(8), 32,251(2)]

S. 11 : Property held for charitable purposes-Accumulation-Not routed through income and expenditure Account-Addition is deleted-Nodal agency for rebuilding portions of the State of Uttarakhand affected by floods-Income-Received funds for rebuilding flood-hit State-Utilised funds as per requirements of State Government-Balance remaining after work repayable to payer-Assessee is not owner of funds-Funds not income-Addition is deleted.[S. 4, 11(2)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Supply of drawings and designs-Plant and equipment supplied from outside India and sale transaction concluded outside India-Receipts cannot be taxed in India-Amount not taxable in India-Receipts from supervisory services for erection and Commissioning of equipment-Amount received falls within definition of fees for technical services-DTAA-India-Switzerland, Switzerland.[Art. 12(4)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Deduction of tax at source-Non-Resident-Software development services rendered to overseas client-No transfer of specialised technical knowledge-Not fees for technical services-Not liable for tax deduction at source-DTAA-India-USA [S.195, Art.12]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Non-Resident-Royalty-Licence to incorporate software belonging to non-Resident in Indian company’s Vehicles-Receipts from supply of software is not royalty-Receipts business income not taxable in India in absence of a Permanent Establishment in India-Delay in filing of return-Extended notification-Matter remanded for verification-Interest-Income received after deduction of tax at source-Levy of interest is not valid-DTAA-India-China. [S.9(1)(vi), 139, 209(1)(d), 234A, 234B, Art. 12(3)]

S. 6(1) : Residence in India-Individual-Non-Resident-Once assessee qualifies as non-Resident salary received by assessee while rendering service abroad not taxable in India-DTAA-India-United Kingdom [S.5(2)(b), Art, 16.]

S.147: Reassessment – After the expiry of four years – Short term capital loss – Long term capital gains – No specific allegation in the reopening notice to disclose any material facts- Reasons for reopening were based entirely on records already available during the original assessment- Reopening notice, order disposing the objection order, reassessment order, and the demand notice is quashed and held as invalid.[ S. 45 , 148 Art. 226 ]

S. 68 : Cash credits – Sale of shares –Explained the nature and source – Investment and the transaction was part of a larger acquisition by KKR Group – Order of CIT(A) deleting the addition is affirmed .[S. 115BBE , 133(6) ]

S.54F : Capital gains- Investment in a residential house -Joint property purchase with wife –Joint transfer for consideration- s The wife’s inclusion in the property title was deemed nominal and for convenience- Denial of exemption is not valid .[ S. 45, Transfer of Property Act, 1882, S.45 ]