S. 11 : Property held for charitable purposes-Delay of 852 days in filing the appeal is condoned-Late filing of Form No 10B-CIT(A has no power to condone the delay-Tribunal condoned the delay and directed the Assessing Officer to verify the Form No 10B in accordance with provisions of the Act-Circular No 2 of 2020 dt. 3-1-2020. [ S.11, 12, 143(1), 249(3), Form No 10B]

S. 11 : Property held for charitable purposes-Managing trustee is paid unreasonable and excessive salary-Failure to prove that the vehicle was used for performing its charitable activity-Foreign tour of manging trustee-Denial of exemption is justified-When there is violation of section 13(2) and 13(1)(c), the trust has to be taxed at maximum marginal rate under section. 164 (2) on its income.[ S. 13(1)(c), 13(2)(c), 164(2)]

S. 11 : Property held for charitable purposes-Assessment completed before grant of registration-Exemption is not available.[ S. 12A(2), 12AA, 148]

S. 10AA : Special Economic Zones-Failure to file e. file Form No. 56F along with the return-Form was filed during the assessment proceedings. [ S.80IA(10), Form No. 56F]

S. 10AA : Special Economic Zones-Interest income-Profits of the business has to be considered.[S.10AA(7)]

S. 10(1) : Agricultural income-Growing and selling of hybrid corn seeds jointly with help of farmers-Ownership or possession of land is not a pre-condition for claiming agricultural operations to be carried out under section 10(1)-Entitled to exemption.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Advisory services-Intergroup services-Make available-Human resources-Receipts is not taxable as Fees for technical services-DTAA-India-UK. [ art. 13]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Fees for included services-Conceptual design services-Make available-Designs, drawings, lay-outs etc. provided by assesse-Not assessable as fees for technical services-DTAA-India-USA [S.115A, art. 12(4)(b)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-Videos on database-Learning platform on its website-Subscription revenue-Subscription fees could not be said to be for imparting of any information concerning industrial, commercial or scientific experience-Not taxable as royalty-DTAA-India-USA. [S.9(1)(vii), art. 12(3)(a)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Payment of compensation to overseas cricket association-Premature termination of agreement-Payment is not chargeable to tax in the hands of South Africa Cricket Board-Cricket South Africa (CSA)-No obligation to deduct tax at source-No Permanent Establishment in India-DTAA-India-South Africa. [S. 5(2), 90, 115BBBA, 194E, 195 Art.5(5), 7]