S. 11: Property held for charitable purposes-Revised return-Break-up of foreign contribution as ‘corpus fund donation’ or ‘other than corpus fund donation’-Failure to upload revised return-Revised return which assessee could not file due to technical glitches was to be considered by Assessing Officer subject to verification of donations and to allow claim for exemption under section 11 to assessee-trust [S. 12, 139(5), 143(1), 154]

S. 10(10AA): Leave salary-Employee of the Central Government or State Government-Allowed only partial exemption-Matter was remanded for fresh adjudication in light of said notification and related judicial pronouncements. [S.10AA(ii)]

S. 10(25): Recognised Provident Fund-Exemption-Income of recognised PF not taxable. [S.10(23AAA, 10(25)(ii), 139]

S. 10 (23C): Educational institution-Approval-Exemption claimed u/s 10(23C)(iiiad)-Only after receipt of approval u/s 10(23C)(i) r.w.s. 10(23C)(vi) for the relevant year-held, it was entitled to claim exemption u/s 10(23C) even though it was not registered u/s 12A[S. 10(23C(1), 10(23C)(vi), 12A]

S. 10(23AAA): Funds established for the welfare of employees-Army school established and funded by the regimental fund of the Indian Army-Welfare of defence personnel-The matter was remanded to the Assessing Officer for fresh consideration.

S. 9(1)(vii): Income deemed to accrue or arise in India-Royalty/FTS-Foreign company-Taxability of (i) receipt from sale of designs and drawings and (ii) Offshore supply of plants and equipment-Reimbursement for SAP installation-No PE-Not taxable as FTS or royalty-DTAA-India-Germany.[Art. 12]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-AO taxed the services of the Assessee as FTS-Held, AO did not clarify what information was required from Assessee-Addition is deleted-DTAA-India-Singapore.[Art. 12(4)(b)]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Royalties-Consideration from licensing of software and support services-No permanent establishment-Non-taxable business income in the absence of any Permanent Establishment-Addition as FTS/FIS was deleted-DTAA-India-France.[S.9(1)(i), 9(1)(vi, 90, Art. 12]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Make available-IT support services to its Indian AE-Non support services-Amount received was not taxable as FTS-DTAA-India-UK [Art. 13]

S. 9(1)(vii): Income deemed to accrue or arise in India-Fees for technical services-Sale of software products to Indian distributors for onward resale to end-users-Product simpliciter facilitating digital security and not for rendering technical services, such income was not taxable in India as FTS-DTAA-India-Ireland [Art. 12 (3)(b)]