S. 10(23C) : Educational institution-Retrospective withdrawal of approval-Approval can be withdrawn only from the date of issuance of the show cause notice-Chairperson-Occupying the house property in lieu of her services-Provision for vehicles for members of the Society-Withdrawal of exemption is not justified. [S. 10(23C)(vi)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-No evidence was available to ascertain the precious nature of actual services rendered-Matter remanded to the Assessing Officer-DTAA-India-USA. [S. 90, art. 12(4)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-No right in the domain name-Income received from domain name registration is not royalty-Web hosting-Does not constitute royalty-Conducting conference for two days cannot be considered as fixed place of business and excluded from the definition of Permanent Establishment- DTAA-India-UAE. [S. 90, art. 5(3), 7, 12]

S. 4 : Charge of income-tax-Joint venture of Central Government and State Government-Rail corporation-Metro rail project-Separate legal entity-Income derived from corporation from business activities could not be said to be income of Karnataka State Government under article 289-Capital or revenue receipts-Sales tax referred-Matter remanded to the Assessing Officer-Interest on fixed deposits-Interest earned from fixed deposits of surplus funds after commencement is taxable though it was received for expansion of the project. [Companies Act, 1956, art. 12, 289]

S. 4 : Charge of income-tax-Capital or revenue-Sales tax subsidy-Backward area-Capital receipts.

S. 271G : Penalty-Documents-International transaction-Transfer pricing-Neither Assessing Officer nor Commissioner (Appeals) asked to furnish any specific information or documents-Penalty is deleted. [S. 92B,92D(3), 273B]

S. 271(1)(c) : Penalty-Concealment-Pendency of quantum appeal before CIT(A)-Assessing Officer at liberty to proceed in accordance with law after decision of pending quantum appeal.

S. 271(1)(c) : Penalty-Concealment-Undisclosed income determined based on materials seized during search-Not a case of estimation of income-Penalty is justified.[S. 69, 132, 153A]

S. 271(1)(c) : Penalty-Concealment-Failure to indicate limb under which proceedings initiated-Penalty is deleted. [S.133A]

S. 271(1)(c) : Penalty-Concealment-Business loss-Carry forward and set off-Pendency of appeal-Claim cannot be termed incorrect or erroneous or false —Levy of penalty is not justified.