S. 11 : Property held for charitable purposes-Form No 10B was not uploaded along with return-Procedural defects-Procedural defect which was rectifiable, issue was to be restored to Assessing Officer to adjudicate afresh. [S. 11, 12A, Rul3. 17B , Form No 10B]

S. 11 : Property held for charitable purposes-Development agreement-Advance received-Transaction of sale is concluded after grant of approval by Charity Commissioner vide order dated 31-3-2021-No addition can be made for the relevant assessment year-Notional interest-No real interest was accrued or received nor same was recorded by assessee in its books of account, addition made on account of notional interest by Assessing Officer is deleted [S.12A, 13(1)(c) ,13(2(a), 22 , Bombay Public Trust Act, 1950 , S.36]

S. 11 : Property held for charitable purposes-Donations from various donors-Small portion retained to meet administrative expenses-Remaining donations distributed to various charitable organisations-Matter remanded to the Assessing Officer to decide the claim in accordance with law laid down by Supreme Court in case of Asstt. CIT (E) v. Ahmedabad Urban Development Authority. [S. 2(15), 12AA]

S. 11 : Property held for charitable purposes-Educational activities-Not registered under section 12A-Computation has to be done under normal provision of the Act-Corpus donation of Trust-Addition cannot be made while computing as per normal provisions of the Act-Anonymous donations-Only applicable to trusts which are registered under section 12A, and does not deal with unregistered charitable trusts-Donations cannot be added as cash credits. [S. 12A 68, 115BBC , 158BC]

S. 10(38) : Long term capital gains from equities-Additional evidence-Directed the Assessing Officer to admit the additional evidence and allow the claim of exemption.[S.45 , 68 , 250]

S. 10(23B) : Khadi or Village Industries-Period for which certificate is to be granted is not within control of assessee-Technical violation-Denial of exemption is not justified.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Royalty-Intra-group services agreement with its India affiliates, services provided in relation to marketing and sales services-Services did not ‘make available’ technical knowledge, experience, skill, know-how or processes and there was no transfer of technology-DTAA-India-Singapore [S.9(1)(vi) , art. 12(4)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-No make available clause-IT services to Indian customers-Taxable in India-Fee for providing corporate guarantee to its Indian AE-DTAA-India-Finland.[S. 56, art. 5, 7 , 12 , 21]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Payment of destination sampling charges to non-resident service providers for services rendered by them outside India-Payment is not taxable-DTAA-India-China [art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Roaming services to its customers while travelling to UK-roaming charges paid to assessee would not fall within scope and meaning of royalty-DTAA-India-UK [Art. 13]