S.14A : Disallowance of expenditure-Exempt income-Restriction of disallowance to the extent of two per cent. of dividend income Proper-Reserves and surplus amount exceeding investment-Presumption that investments out of own interest-bearing funds Disallowance not attracted.[S. 36(1)(iii) R.8D, 260A]

S.14A : Disallowance of expenditure-Exempt income-No borrowed funds utilised for investment-Order of Tribunal deleting the disallowance affirmed.[R.8D(2)(iii)]

S. 10 (23C): Educational institution-Ancillary activities were connected with the main activity of imparting education-Nominal profit earned was again utilised for the main object of education-Entitled to exemption. [S. 10(23C)(vi), 260A]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Non-resident-Providing registration for a domain name-Fees received not assessable as royalty-DTAA-India-USA (1991) 187 ITR (St.) 102). [S.260A, Art. 12(3)(a)]

S. 9(1)(i): Income deemed to accrue or arise in India-Business connection-Shipping business-Freight charges collected in India-Certificate from tax authorities that amount was assessable in Singapore-Earning not taxable in India-DTAA-India-Singapore-(1994) 209 ITR (St.) 1) [S.44B, Art. 24]

S.50: Benami transactions-Offences and prosecution-Demonetisation-Jurisdiction of court-Complaint filed before Special Court under Benami Prohibition of Benami Property Transactions Act Cognizance of offence by trial court Valid Act, 1988. [S. 53, Criminal Procedure Code, 1973, S. 200, 482]

S. 2(1)(a)(ii): Application-Pendency of appeal-Maintainability-Certified order given on 10-7-2020-Application dated 2-5-2020 maintainable-Directed to entertain the application. [Art. 226]

S. 148A: Reassessment-Conducting inquiry, providing opportunity before issue of notice-Death of assessee-Department not informed of death of assessee-Legal heir deemed to be assessee-Directed to respond to notice under section 142(1)-Assessing Officer directed to issue subsequent notices in name of legal heir.[S. 142(1), 148A(b), 148A(d), Art. 226]

S. 10 (23C): Educational institution-Hospital or medical institution Grand-in-aid from Government Effect of section 10(23C) (iiiac)-Interest on grants-in-aid-To be added to grants-in-aid or returned to Government-Interest entitled to exemption [S. 10(23C) (iiiac).]

S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Tribunal holding transfer pricing to be proportionate to value of international transaction-Business expenditure-Provision for warranty-Tribunal deleting disallowance Proper-No substantial question of law. [S.37(1), 260A]