S. 14A : Disallowance of expenditure-Exempt income-Interest on borrowed capital-Investments made from own funds-Disallowance is not justified. [R. 8D, 260A]

S. 10 (23C) : Educational institution-Placement services-Associated with education-Fee charged-Entitle to exemption [S. 10(23C)(vi), Art. 226]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Payments received from Indian customers for centralised services–Not taxable as fees for technical services or fees for included services-DTAA-India-USA. [Art. 12(4)(a)]

S. 2(15) : Charitable purpose-Exemption-Object of general public utility-Clarification-Law declared by court to be applied for assessment years in question, which were before court and were decided-Appeals decided against department, matter to be treated as final-For assessment years not before Court, authorities to apply law declared in judgment, having regard to facts of each year. [S. 10(20A), 10(23C), 10(46), 11, 11(4), 11(4A), 12, 12A, 12AA, 13(8), 143(3)]

S. 2(15) : Charitable purpose-Advancement of object of general public utility-Changes in law after 1-4-2009-Cannot engage in any trade, commerce or business, or provide service in relation thereto for consideration-Activities must be connected to achievement of object of general public utility and receipts therefrom do not exceed quantified limit-Consideration on cost-basis or nominally above cost not Commercial-Charges significantly above cost would fall within mischief of Trade, commerce or business-Assessing Officer has to decide year to year basis-Separate books of account must be maintained-Statutory corporation, Board or any other body set up by State or Central Government for achieving public functions or services-Receipts not business or commercial receipts-Assessing authorities to determine if consideration significantly higher than cost and if so, whether comply with quantified limit-Central Government to decide on case-by-case basis whether and to what extent exemption can be awarded to notified bodies-Denial of benefit after 1-4-2011 does not preclude from claiming exemption under other provisions-Regulatory bodies tasked with exclusive duties of prescribing curriculum, disciplining professionals and prescribing standards of professional conduct-Prima facie not business or commercial receipts-Bodies involved in trade promotion or purely for co-ordinating and assisting trading organisations-Subjected to rigours of proviso-GSI India Services for benefit of trade and business, from which it received significantly high receipts-Exemption denied-State Cricket Associations-Commercial rights-Each case and for every year tax Authorities to examine pattern of receipts and expenditure-Matter remanded-Private Trust for publishing newspaper-Income received from advertisements constitutes business or commercial receipts Not entitled to exemption-Assessee formed with object of running arogya kendra-No Clarity whether supplying Mid-Day meals fell within objects clause of Society-Tax effect less than Rs. 10 Lakhs-Receipts not exceeding quantitative limit-Entitled to registration-Interpretation of taxing statutes-Amending provisions-to be considered in light of history of legislation and what lawmakers intended by amendment-.Aids to construction-Speeches made in legislature can be looked into-Circulars-Binding upon Departmental Authorities if they advance proposition within framework of statute-Not binding where contrary to statute-Not binding on courts. [S. 10(20A), 10(23C), 10(46), 11, 11(4), 11(4A), 12, 12A, 12AA, 13(8), 143(3)]

S. 145: Method of accounting -Valuation of stock -Valuation adopted by Revenue valid — No question of law .[ S.260A]

Interpretation of taxing statutes — Date of applicability of a statutory amendment – Amending provisions — to be considered in light of history of legislation and what lawmakers intended by amendment – .Aids to construction — Speeches made in legislature can be looked into- Circulars — Binding upon Departmental Authorities if they advance proposition within framework of statute — Not binding where contrary to statute—Not binding on courts-Definition — Unless the context otherwise requires . [ S. 10(20A), 10(23C), 10(46), 11, 11(4), 11(4A), 12, 12A, 12AA, 13(8), 143(3)

S. 9(1)(vii):Income deemed to accrue or arise in India – Fees for technical services -Technical services do not include construction, assembly and design — Dominant purpose of contract was supply of passenger rolling stock —Amount received under contract could not be deemed to accrue or arise in India [ S. 194J, 201(IA) ]

Interpretation of taxing statute – The principles of judicial discipline and propriety and binding precedent – Unless there is a stay obtained by authorities under Income-tax Act, 1961 from higher forum, mere fact of filing appeal or SLP will not entitle authority not to comply with order of High Court- Court directed the Registrar General to forward the copy of the judgement for circulating amongst authorities under the Income tax- Act , 19961 and for the observance of the principles of the judicial discipline and propriety. [ Art , 141, 226 , 227 ]

S. 148 : Reassessment –Notice – Challenged on several grounds – writ petition dismissed .[ S. 147, Art , 226 ]