S. 12AA : Procedure for registration-Trust or institution-Collusive arrangement with SRMAMET (a trust formed by same management committee as that of assessee-society)-Funds were channelized directly/indirectly for members of management committee, assessee-society-Violation of section 13(1)(c)-Cancellation of registration is justified. [S. 12A, 12AA(4)(a), 13(1)(c)(ii)]

S. 12A : Registration-Trust or institution-Trust, corpus contribution-Corpus specific voluntary contribution-Trust not registered u/s 12A/12AA of the Act-Capital receipt cannot be assessed as income.[S. 2(24)(iia), 11(1)(d), 12A, 12AA]

S. 11 : Property held for charitable purposes-Accumulation of income-Condonation of delay-Pending for consideration-The Assessing Officer is directed to take a decision in matter after outcome of condonation petition filed by assessee.[S.11(2) 13(9), 139, Form No 10B]

S. 10 (23C) : Educational institution-Assessee has 12 units-Annual receipts of each of the institutions of the Assessee was less than the prescribed limit under the provision-Entitled to the exemption-Directed to give effect to petition filed under S. 154 of the Act. [S. 10(23C)(iiiad), Form No 10BB]

S. 10 (23C) : Educational institution-No disallowance can be made buy applying provisions of section 11 and 12-Grant in aide-Could not be considered as assessee’s income-Exempt from tax-Depreciation-Not claimed cost incurred on acquisition of fixed assets as application of income-Depreciation is allowable. [S.10(23C)(vi), 11, 12, 32]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Subscription fee-Fees for technical services-Subscription payments, training and professional fees-No transfer of technology-DTAA-India-Netherlands [Art. 12]

S. 9(1)(ii) : Income deemed to accrue or arise in India-Salaries-Held, the Assessee, being a non-resident, has rendered services outside India, the salary cannot be taxable in India-DTAA-India-Austria [S. 5,15, Art. 15]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent Establishment-Off shore supply of goods and equipments-Out side India-No Permanent Establishment-Not taxable in India-DTAA-India-Thailand [Art. 5]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent Establishment-Supply and delivery of equipment and supervision, installation, erection and commissioning activity-Single composite contract-Assessee had PE in India-Income attributable to Indian PE from said contracts is taxable in India-Matter remanded to the file of the AO for computation-DTAA-India-Germany. [Art. 5, 7]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Permanent establishment-Agency PE-Indian subsidiary-Advertisement sales agent-Not dependent PE-Not taxable in India-DTAA-India-Mauritius [Art. 5(4)]