S. 115-O : Domestic companies-Tax on distributed profits-Income-Deemed to accrue or arise in India-Dividend-DTAA does not get triggered when a domestic company pays DDT under section 115-O-Order of the AO rejecting the claim of refund of excess DDT is affirmed.-DTAA-India-Italy [S.9(1)(iv), Art. 11]

S. 115BAC : Tax on income of individuals and Hindu Undivided Family-Old scheme-New tax scheme and filed form 10-IE while filing revised return, requirement of filing Form 10-IE was directory in nature and not mandatory and it was sufficient compliance if said form was before Assessing Officer at time of assessment.[S.139(1), 143(1) R. 21AG(1), Form No 10-IE]

S. 80G : Donation-Rejection of application-Pendency of fresh application-Appeal is dismissed as infructuous. [S.80G(5)(viii), Form No 10AB]

S. 90 :Double taxation relief-Investment fund-Capital gains-Shares, units, transfer of-Conduit entity without any economic substance-Not justified in denying benefits under article 13 on long term capital gains-DTAA-India-Mauritius [S.9(1)(i)), 90(2) Art. 13(4)]

S. 80IC : Special category States-Partnership firm to company-Change in status of company in terms of its composition does not brings into action provisions of section 80IC(4)(ii)-Entitle to deduction. [S 80IC(2)(a)(ii), 80IC(4)(ii)]

S. 80G : Donation-Provisional approval-Commencement of activities in 2002-Entitle for final approval and there is no bar for making fresh application.[S.80G(5)(iv)]

S. 80G : Donation-Within six months of commencement of its activities used in clause (iii) of first proviso to section 80G(5) would apply to those trusts which had not started charitable activities at time of obtaining provisional registration and not for those trusts which had already started charitable activities before obtaining provisional registration-Matter remanded for de novo adjudication. [S.80G(5), Form No.10AB.]

S. 80G : Donation-Provisional approval-Commenced it’s activities prior to amendments brought in grant of registration of trust effective from 1-4-2021-Filed application for grant of final approval under section 80G(5) within a period of six months from date of grant of provisional registration within extended timeline upto 30-9-2023-, Application could not be denied on ground that same was not filed before 30-9-2022 as per Circular No. 6/2023, dated 24-5-2023.[S. 12A,80G(5), Form No 10A]

S. 80G : Donation-Commenced its activities much prior to grant of provisional approval under section 80G(5)-Assessee would be entitled to file application for grant of regular approval under section 80G(5) prior to six months of expiry of provisional approval.[S.80G(5), Form No. 10AB]

S. 80G : Donation-Failure to appear before CIT(E)-Rejection of application in limine-Matter remanded back to Commissioner for decision afresh on merits. [S.80G(5)]