S. 10(25): Recognised Provident Fund-Exemption-Income of recognised PF not taxable. [S.10(23AAA, 10(25)(ii), 139]

S. 10 (23C): Educational institution-Approval-Exemption claimed u/s 10(23C)(iiiad)-Only after receipt of approval u/s 10(23C)(i) r.w.s. 10(23C)(vi) for the relevant year-held, it was entitled to claim exemption u/s 10(23C) even though it was not registered u/s 12A[S. 10(23C(1), 10(23C)(vi), 12A]

S. 10(23AAA): Funds established for the welfare of employees-Army school established and funded by the regimental fund of the Indian Army-Welfare of defence personnel-The matter was remanded to the Assessing Officer for fresh consideration.

S. 9(1)(vii): Income deemed to accrue or arise in India-Royalty/FTS-Foreign company-Taxability of (i) receipt from sale of designs and drawings and (ii) Offshore supply of plants and equipment-Reimbursement for SAP installation-No PE-Not taxable as FTS or royalty-DTAA-India-Germany.[Art. 12]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-AO taxed the services of the Assessee as FTS-Held, AO did not clarify what information was required from Assessee-Addition is deleted-DTAA-India-Singapore.[Art. 12(4)(b)]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Royalties-Consideration from licensing of software and support services-No permanent establishment-Non-taxable business income in the absence of any Permanent Establishment-Addition as FTS/FIS was deleted-DTAA-India-France.[S.9(1)(i), 9(1)(vi, 90, Art. 12]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Make available-IT support services to its Indian AE-Non support services-Amount received was not taxable as FTS-DTAA-India-UK [Art. 13]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Sale of software products to Indian distributors for onward resale to end-users-Product simpliciter facilitating digital security and not for rendering technical services, such income was not taxable in India as FTS-DTAA-India-Ireland [Art. 12 (3)(b)]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping, Inland waterways transport and air transport-International traffic-UK tax resident airline-Received delivery order charges in connection with transportation of passengers, mail, livestock and goods by air in international traffic-Considered directly connected with operation of aircraft under Article 8(3) of India-UK DTAA and thus, would not be taxable in India-DTAA-India-UK [Art. 8]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping, Inland waterways transport and air transport-International traffic-Operation of ships in international traffic-Multiple ports in India-Benefit of Article 8 of India-UAE DTAA was to be extended to entire freight receipts irrespective of whether earnings were relating to feeder vessels or by ships in international traffic-Profit derived from shipping business as envisaged under article 8 of India-UAE DTAA and was not taxable as business profit in India-DTAA-India-UAE [Art 8]