S. 14A : Disallowance of expenditure-Exempt income-Investments held as Stock In Trade cannot be subject matter of disallowance-Strategic investments yielding exempt income alone to be considered for purpose of working of disallowance. [R. 8D(2)(iii)].

S. 14A : Disallowance of expenditure-Exempt income-Investment was made in earlier year-No interest expenditure was claimed-Matter remanded to the AO for fresh consideration. [R. 8D]

S. 14A : Disallowance of expenditure-Exempt income-Investment made in earlier years-Disallowance to be restricted to extent of funds invested. [R. 8D]

S. 12AA : Procedure for registration-Trust or institution-Running Educational Institutions imparting engineering courses-Recognised by All India Council for technical Education and Establishing Polytechnic College-Genuineness established-Eligible for grant of Registration-Grant of approval u/s. 80G only after satisfying conditions. [S.2(15), 80G]

S. 11 : Property held for charitable purposes-Object of promoting growth of Automobile Industry In India and also to improve and protect environment-Entitled to exemption-Corpus fund-Amount transferred is not application of income-Foreign grants-Pending for approval-Characterisation of receipt as taxable income only at time of appropriation and not at time of receipt-Not income of assessee-No quantum additions-Penalty not leviable. [S. 2(15), 12, 12A, 271 (1)(c), Foreign Contribution (Regulation) Act of 2010, S.11 (1)]

S. 11 : Property held for charitable purposes-Corpus donations-Capital receipt-Market rent-Rent received far more than valuation of Municipal Corporation of Delhi-Rent increased to 10% every three years as per Delhi Rent Control Act, 1958-Exemption cannot be denied. [S. 11(1)(d), 13(2)(b), 13(3)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Employees of Non-Resident assessee deputed to manage affairs of its associated enterprise in India and provide technical Knowledge-Employees continuing to make social security contributions in their country and their salaries distributed to their bank accounts-There-Revenue received by assessee by way of reimbursement constitutes fees for included services-DTAA-India-USA. [Art. 7]

S. 2(22)(e) : Deemed dividend-Current account transactions outside purview of deemed dividend-Rule of consistency is followed.

S.132: Search and Seizure – Firm – Person actively involved in the activities of the firm – Search is held to be valid – Order of Tribunal is affirmed . [ S.40A(3), 68 )

S. 147: Reassessment – Anonymous donations -Appeal pending on similar issue in another issue- Notice not to be quashed – Order of High Court remanding the matter was affirmed [ S. 115BBC , 148 ]