S. 12AA : Procedure for registration-Trust or institution-Denial of registration was not valid on the ground that the assessee has wrongly claimed exemption under sections 10(23BBA) and 10(23C)(v)-Registration under section 12AA was not dependent either upon section 10(23BBA) or 10(23C)(v)-Directed to consider application under section 80G for approval afresh. [S. 10(23BBA), 10(23C)(v), 11, 12A, 89G]

S. 12AA : Procedure for registration-Trust or institution-Amounts set apart for specific purposes-No assessment-Cancellation of registration is held to be premature [S. 12A, 12AA(4), 13, 132, 133A]

S. 10A : Free trade zone-Eligible undertaking-Gross total income-After amendment of section 10A by Finance Act 2000, said section became a provision for deduction but stage of deduction would be while computing gross total income of eligible undertaking under Chapter IV of Act and not at stage of computation of total income under Chapter VI of Act.

S. 10 (23C) : Educational institution-Audit report submitted before completion of assessment-Registration under section 12AA is not a condition precedent for availing the exemption under section 10(23C)(v)-Exemption cannot be denied merely on ground that the assessee has generated surplus income. [S. 10(23C)(v), 11, 12AA]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Make available-Business support services-Receipts from said services would not be treated as FTS-DTAA-India-Singapore. [Art. 12(4)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Sale of software-Not taxable as Fees for technical services-DTAA-India-Singapore. [S. 9(1)(vi), Art. 12(4)(a), 12(4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Indian Hotels-Providing services like worldwide publicity, marketing and advertisement services-Consideration received is not taxable as FTS-DTAA-India-USA. [S. 9(1(vi), 90, Art. 12(4)(a), 12(4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Commission-Sales promotion-No permanent establishment-Not taxable in India-Not liable to deduct tax at source-DTAA-India-USA-UK. [S. 195, Art. 7]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Educational institute-Sharing of database-Service agreement-Matter remanded-DTAA-India-Malaysia [S. 9(1)(vii), Art. 12(3)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Computer software-Royalty-Fees for technical services-Attributable profits-Matter remanded to the file of AO for de novo adjudication-DTAA-India-Portugal. [S. 9(1) (vii), 147, 148, Art. 12]