S. 11: Property held for charitable purposes-Accumulation of income-Educational purpose-Board resolution-Providing scholarship-Form No 10B-Entitled to claim benefit of section 11(2).[S.11(2), Form No 10]

S. 11: Property held for charitable purposes-Accumulation of income-Amendment brought in by Finance Act, 2022, did not debar assessee from availing said time window in respect of existing accumulations and amendment had to be read prospectively in respect of fresh accumulations for the period pertaining to previous year starting from 1-4-2022 onwards. [S.11(3)(c)]

S. 9(1)(ii): Income deemed to accrue or arise in India-Salaries-Non-resident-Employed with TCS Malaysia-Rendered his services in Malaysia-Taxable in Malaysia even though the same was received in India-DTAA-India-Malaysia [S.5(2) Art. 16]

S. 10 (23C): Educational institution-Clerical omission, deduction was claimed under section 10(23C)(iiiad) instead of the correct section 10(23C)(vi)-Order of Assessing Officer rejecting the request for rectification was set aside. [S. 10(23C)(iiiad), 10(23C)(vi), 11,12, 12AA Form No.10B]

S. 10 (23C): Educational institution-Delay in filing application-No mala fide conduct or gross negligence-Delay was condoned-Matter was remanded to the file of CIT (E). [S.10(23C)(5)]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Income from providing centralized group services such as communication, marketing, strategy, HR, treasury, finance-Taxable in India as fees for technical services-Guarantee fee from its Indian subsidiaries for providing corporate and performance guarantees, since providing guarantees was not a regular business activity but an obligation arising from parent–subsidiary relationship, such fee was taxable in India as other income-DTAA-India-Finland.[Art. 7, 12, 21]

S. 4: Charge of income-tax-Subsidy-Industrial Promotional Subsidy from State Government-Matter remanded to the file of CIT(A) for adjudication afresh.[S. 2(24)(viii)]

S. 4: Charge of income-tax-Capital or revenue-Subsidy-Income received on sale of Market Linked Focus Product Scheme (MLFPS) scrips was a capital receipt.[S. 2(24)(xviii) 28(i)]

S. 2(22)(e): Deemed dividend-Advance salary to director-Disallowance cannot be made.

S. 2(14)(iii) : Capital asset-Agricultural land-Capital gains-Failed to prove that distance from municipal limits exceeded 8 kms,-land constituted capital asset under section 2(14) and liable to capital gains tax.[S. 2(14),2(14)(iii)(b), 45]