S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty Amounts paid as consideration for resale/use of computer software through EULAs/distribution agreements-Not payment of royalty for use of copyright-Does not give rise to any income taxable in India-Not liable to deduct any TDS under section 195 of the Act. [S. 195]

S. 4 : Charge of income-tax-Mutuality-Club-Guests fees from members, hire charges, income from rooms and housie participation fees-Not chargeable as income.

S. 4 : Charge of income-tax-Accrual of income-Retention money Retained by Electricity Board subject to fulfilment of no-defect or liability-Cannot be treated as income-Sum taxable only in year of receipt or accrual. [S. 5, 145]

S. 11 : Property held for charitable purposes – Education – Study and promote the latest development in the filed of Architecture – Mere surplus arising as a result of charitable activities the Institution does not cease to be a charitable institution – Entitle to exemption. [ S. 2(15), 12A, Architect Act , 1872 ]

S.69A: Unexplained money – Demonetization – AIR information -Amount deposited to bank from earlier withdrawals – Addition was deleted – Cash Deposits in Partnership Firm’s bank Account – Amount transferred to partner’s account as withdrawal from capital –Addition cannot be made in the hands of partner . [ S. 2(31)iv),133(6)]

S. 123(e) : Municipal Property Tax-Exemption-Hospital-Hospital run by Society-Objects of society was not purely charitable-Exemption from Income-tax Act, 1961 was not granted-Hospital not exempt from Municipal Property Tax. [IT Act, 1961, S. 11, 12,12A, Companies Act, 2013, S. 135].

S. 2(1)(a)(i) : Appellant-Protective assessment-Amounts paid under protective assessment must be returned to assessee-Same income cannot be assessed in hands of assessee more than once-The Act is not intended either to collect or retain any amount which is not due from an assessee. Under section 237 under Chapter XIX of the Income-tax Act, 1961, there is no limitation prescribed for granting refund of the amount paid in excess as tax. [IT Act, S. 143(3), 154, 237, 244A, Art. 226]

S. 2(1)(a)(i) : Appellant-Delay in filing appeal condoned-Deemed to have been filed before expiry of limitation-Rejection of declaration was not valid. [Art. 226]

S. 279 : Offences and prosecutions-Sanction-Chief Commissioner-Commissioner-Compounding of offences —CBDT Circular issued in 2019-Assessee over 70 years-Discretion to compound offences-Paid tax, penalty and interest-Directed to consider the application for compounding the offence. [S. 119(1), 271(1)(c), 273A, 276C, 277, 279(2), Art. 226]

S. 276C : Offences and prosecutions-Wilful attempt to evade tax-Rejection of application for compounding of offences-Contempt proceedings-Directions Issued by Court in contempt petition-Court cannot issue directions traversing beyond its scope of jurisdiction-Liberty was granted to the assessee to file a fresh application for compounding of offences and put forth all his contentions. [S. 277, 279, Contempt of Courts Act, 1971, S. 11, 12, Art. 226]