S. 11 : Property held for charitable purposes-General utility to public–Acquisition and sale of immovable properties-Issue is remanded to Assessing Officer to consider afresh strictly in light of observations made by Apex Court in CIT(E) v. Ahmedabad Urban Development Authority (2022) 291 Taxman 11/ 449 ITR 1 (SC). [S. 2(15)]

S. 11 : Property held for charitable purposes-Application of income-Less than 85 per cent of total receipts-Matter is remanded for de novo adjudication before NFAC. [S. 12A,250, Form No 10]

S. 11 : Property held for charitable purposes-Fresh registration under section 12AB-Original registration under Section 12AA up to Assessment year 2021-22-Denial of exemption is not valid.[S. 12AA, 12AB, 13]

S. 11 : Property held for charitable purposes-Loan scholarships to Indian students in India for education/higher education abroad-Application of income-Eligible for exemption. [S.11(1)(c)]

S. 11 : Property held for charitable purposes-Sale of property-Invested in bank fixed deposit-Converted into capital gain account scheme-Utilised entire amount of capital gain for purchasing other property in financial years 2022-23 and 2023-24-Instruction No. 883, dated 24-9-1975-Entitle to exemption.[S 11(1), 11(5), 11(IA)]

S. 11 : Property held for charitable purposes-Research work in area of micro wave electronics-No changes in facts-Denial of exemption is not valid.[S. 2(15) 12A]

S. 10(38) : Long term capital gains from equities-STT was not paid at time of acquisition of shares-Entitle to exemption. [S.115U]

S. 10 (23C): Non profit organization-Promoting export of leather industries-Objectives of general public utility-Net surplus was less than 20 per cent of total receipts-Exemption cannot be rejected under second proviso to section 2(15).[S. 2(15), 10(23C)(iv)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Marketing services-Commission on sales-Subsidiary of SEPL India-Performed pure sales function by connecting potential customers from US by performing presales activity of introducing SEPL India-Not taxable in India-DTAA-India-USA[Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Offshore sales of books/journals or providing access to online journals/online library-Not royalty-Services of providing access to online database/journals did not fall under FIS as services did not satisfy clause make available as required for provisions of article 12 of DTAA-India-USA [S.9(1)(vii), Art. 12]