S. 90 : Double taxation relief-Tax credit-Tax paid in Kenia-Rule 128 was inserted by Income-tax (18th Amendment) Rules, 2016 and was made applicable with effect from 1-4-2017,-Could not be made applicable for relevant assessment years-Claim is allowed-DTAA-India-Kenia [S.91, R. 128, Form No 67, Art. 25]

S. 90 :Double taxation relief-Rule 128 is directory in nature and not mandatory and, thus, foreign tax credit could not be denied to assessee merely on ground that Form No. 67 was filed belatedly.[Rule 128, Form No 67]

S. 80P : Co-operative societies-Interest-Co-Operative banks-Interest income not attributable to main business-Deduction is not allowable-Interest on investment made in Co-Operative banks-Eligible for claim of its cost of funds on entire interest income-Matter remanded. [S. 57, 80P(2)(a)(i), 80P(2)(d)]

S. 80JJAA : Employment of new workmen-Audit report-Claim of deduction cannot be denied even if audit report might not have been filed along with return of income however the report was filed before passing of assessment order. [S. 139(1), 139(4), 143(1), Form No 10DA.]

S. 80G : Donation-Application was rejected on the ground that application was not within six months from date of provisional approval-Since provisional approval granted to assessee was valid till assessment year 2024-25-Application filed by assessee being within time limit permissible under section 80G(5)(iii), was to be restored to file of Commissioner (E) for de novo consideration. [S.80G(5)(iii)]

S. 80G : Donation-Approval-Application was filed beyond six months of commencement of activities-Tribunal directed the Commissioner (E) to grant exemption registration under section 80G(5)(iii) of the Act. [S.80G(5)(iii), Form No 10AB]

S. 80G : Donation-Corporate Social Responsibility (CSR) activities-Mandatory nature of CSR expenditure does not justify disallowance of same under section 80G, if other conditions of section 80G are fulfilled.[S. 37(1), Companies Act 2013 S. 135]

S. 80G : Donation-Rejection of application-Delay in filing Form No 10AB-Matter is remanded to CIT(E) for reconsidering Form No. 10AB for final registration under section 80G(5) by providing opportunity of proper hearing.[S.80G(5), Form No. 10AB]

S. 80G : Donation-Expenditure towards CSR activities are an allowable.[S.37(1)]

S. 80G : Donation-Failure to file submission-Matter remanded back to Commissioner (E) to consider case of assessee on merit and examine object and activities of assessee and pass order in accordance with law.[S.80G(5), R. 17A, Form No. 10AB]