S. 12AA: Procedure for registration –Trust or institution-Application filed but not disposed of-No evidence showing application pending before CIT (E)-One sided correspondence not proof.[S. 12A]

S. 12A : Registration –Trust or institution-Beneficiaries are members of general public-Conducting workshops to disseminate knowledge of Vedas-Financial assistance and distribution of food-Entitle to registration and approval under section 80G of the Act. [S.80G]

S. 12A : Registration –Trust or institution-Exemption-Failure to furnish audit report within specified time-Procedural and technical requirements of e-filing-Subsequent filing of audit report electronically and seeking rectification-Assessing Officer is directed to accept audit report and decide thereon. [S. 11, 12A(1) (b),143(1), 154, Form No. 10B]

S. 12A : Registration –Trust or institution-Registration-Registration granted on 21.07.2011-Proceeding pending for earlier years before AO-Eligible for deduction. [S. 11, 12,]

S. 10 (23C) : Educational institution-Exemption-AOP formed solely for education-No distribution of profit-Income only from educational fees and Bank interest on FDs-Surplus utilised only for education-No contrary evidence-Assessee entitled to exemption.[S. 10(23C)(vi), Form No 10BB, 56D]

S. 10(1) : Agricultural income-Engaged in producing foundation seeds and selling to various seed companies-Engaged labours and supervisors-Operation not of contract farming-Exemption justified.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Assessee providing legal services to clients in India and abroad-No permanent establishment in India-Services not making available technical knowledge, skills know-how process-Income not taxable-DTAA-India-United Kingdom. [Art 4,5,7, 13]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Reimbursement of salaries paid to employees-Employees were high level technical executives-Payments fell under technical services-Tax deducted at source not relevant-Payment taxable. [Explanation. 2]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty- Non-Resident-Use of Transponder services-Secret formula or process-Not liable to tax in India-Not liable to deduct tax at source-DTAA-India-Malaysia [Art. 12, 13]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Not-For-Profit entity incorporated in U. S. A. and exempt from Federal Income-Tax-Providing consulting and education and teaching programs to Hospitals, Medical Schools, Healthcare Institutions under agreements with Medical Institutions-Receipts are not taxable in India-Reimbursement of expenses also not taxable-DTAA-India-USA.[S. 9(1)(vi), 9(1)(vii), Art. 7, 12(3) 12(4)(b), 12(5)(c)]