S. 11: Property held for charitable purposes-Accumulation of income-Belated exercise of option during assessment proceedings]-The Assessing Officer was directed to allow the claim of deemed application of income. [S. 11(1), 12A,12B 143(3)]

S. 11: Property held for charitable purposes-Omission to show application of funds in the IT return-Denial of exemption was not justified.[S. 12, 139]

S. 11: Property held for charitable purposes-Change of name]-Not applied for fresh registration-Assessed under the normal provisions of the Act]-All permissible deductions, including expenditure incurred out of said income, allowable as deduction-Matter restored to the file of the Assessing Officer. [S. 12A, 37 (1)]

S. 10 (23C): Educational institution-Filing of return-total income of the assessee without giving effect to the provisions of s. 10(23C)(iiiad)] exceeded the maximum amount not chargeable to income-tax-Not required to file return of income either under section 139(1) or under section 139(4C)]-Return filed in response to section 148 cannot be treated as invalid]-Disallowance of claim was not justified. [S. 10(23C)(iiiad), 139(1) 139(4C), 148]

S. 10AA: Special Economic Zones-Non-submission of audit report along with return-Audit report was filed during assessment proceedings]-Exemption cannot be denied merely on account of delay in furnishing the audit report.[Form No 56F]

S. 9(1)(vi): Income deemed to accrue or arise in India]-Royalty-license fee for granting broadcasting right-Not royalty]-Apportionment of license fee-‘live coverage’ of the event has very large viewership as compared to a recorded broadcast and, therefore, it is appropriate to allocate 10 per cent of the license fee for broadcasting rights towards recorded events and 90 per cent towards ‘live coverage-DTAA-India]-USA.[S.90, Art. 12(3)]

S. 4: Charge of income-tax -Accrual-Interest receivable from foreign subsidiaries-Financial year-Failed to reconcile- Addition is affirmed.[S. 5, 145]

S. 2(22)(e) : Deemed dividend-Loan received from third parties not related to the company in which the assessee had a substantial interest- Difficult to presume that there was an arrangement or colourable device in respect of the transactions-loans received by the assessee from Sunil Jain and Heera Lal Modi cannot be treated as deemed dividend.

Black Money (Undisclosed Foreign Income and Assets) and Imposition Act, 2015.

S. 10: Assessment-Undisclosed asset located outside India-Bank account outside India-Documents were given to the bank much before the enactment of Black Money Act-Inheritance-Income earned abroad-Addition was deleted. [S. 10(3)]

S. 271(1)(c): Penalty-Concealment-Addition on account of notional rental income-Rental income-Arithmetical error-There was a shortfall in disclosing rental income-Voluntary disclosure of income to cover any omission-No concealment penalty-Appeal admitted by High Court-No penalty-Penalty order barred by limitation. [S. 245(2C), 245 D(4), 275(1)(c)]