S.14A: Disallowance of expenditure-Exempt income-Sufficient interest-free funds available-No disallowance warranted. [R. 8D]

S.14A: Disallowance of expenditure-Exempt income-Dissatisfaction of Assessing Officer must be based on cogent reasons-Mere observation that disallowance is meagre is insufficient. [R. 8D]

S. 12AA: Procedure for registration-Trust or institution-Cancellation-Reference by Assessing Officer after conclusion of assessment proceedings-Reference to Principal Commissioner without jurisdiction-Cancellation of registration held invalid–Provision inserted with effect from 1-4-2022-Not applicable to earlier assessment years-Show-cause notices and cancellation order quashed-Direction that cancellation would survive irrespective of finding on specified violation-Colourable exercise of power-Order quashed. [S. 12AB(4), 127(2), 143(3)]

S. 10AA: Special Economic Zones-Newly established units-Allocation of head office expenses-Common expenses having direct nexus with eligible unit-Allocation in ratio of turnover held justified-Transfer of goods to eligible unit-Market value-Notional gross profit adopted by Assessing Officer-Matter remanded [S.10AA(9), 80-IA(8)]

S. 10AA : Special Economic Zones-Export-Interest income forming part of business profits-Eligible for deduction.

S. 10A: Free trade zone-Export profits-Deduction-Export proceeds realised in convertible foreign exchange-Matter remanded for verification-Communication expenses to be excluded from both export turnover and total turnover-Foreign exchange fluctuation gain-Already offered to tax-Matter remanded to avoid double taxation.[S. 144C]

S. 10(23D): Mutual Fund-Income-Exemption-Scheme vested in UTI Mutual Fund-Separate SEBI registration for each scheme not necessary-Exemption allowable. [Unit Trust of India (Transfer of Undertaking and Repeal) Act, 2002, Sch. II, Entry 37]

S. 9(1)(vii): Income deemed to accrue or arise in India-Non-resident-Warehousing charges paid outside India-Not Fees for Technical Services-No liability to deduct tax at source-DTAA-India-USA [S. 195, Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Non-resident-Marketing services-Sales commission-Not Fees for Included Services under India-USA DTAA-Not taxable in India-DTAA-India-USA-Delay of 89 days was condoned. [S. 254(1) Art. 12(4)(b)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Non-resident-Technology and strategic information system services rendered outside India-No right to use software or intellectual property granted-Receipts not taxable as royalty-Management service fees-General management services rendered to group companies-Neither royalty nor Fees for Technical Services-Not taxable in India-DTAA-India-France. [S. 9(1)(vii), Art. 12]