S. 10(23C) : Educational institution-Filing of audit report along with the return of income is not mandatory-Report cab be filed in the course of assessment proceedings or even appellate proceedings. [S. 10(23C)(vi), Form No. 10BB]

S. 10(23C) : Educational institution-Search and seizure-Withdrawal of registration retrospectively with effect from,2009-Notification No. SO 3215(E), dated 5-9-2019 came into effect from 5-11-2019-Order of withdrawal of exemption was held to be not valid. [S. 10 (23C)(vi)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Management fees-Indian subsidiaries-Most favoured Nation (MFN) clause-Not taxable as fees for technical services-Training services-Matter remanded-DTAA-India-Sweden. [Art. 10, 12(4)(b)]

S. 9(1)(ii) : Income deemed to accrue or arise in India-Salaries-Dependent personal services-Non-Resident-Salary and allowance outside India-Failure to produce tax residency certificate-Not taxable in India-DTAA-India-Belgium. [S. 5(2), 15, 90(4), Art. 15(1)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Re insurance business-Service / dependent-Agreement with Indian subsidiary-DTAA-India-Switzerland. [Art. 5, 7]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Reimbursement of software licence fee-Not liable to be taxed as royalty-DTAA-India-Swedish. [Art. 12]

S. 6(1) : Residence in India-Individual-Out side India for a period more than 182 days-Salary income received by assessee outside India from a foreign employer for services rendered outside India could not be brought to tax in India. [S. 5]

S. 6(1) : Residence in India-Individual-Out side India for a period more than 182 days-Salary income received by assessee outside India from a foreign employer for services rendered outside India could not be brought to tax in India. [S. 5]

S. 5 : Scope of total income-Accrual of income-Sale proceeds-Memorandum of understanding (MoU) with SIPL to invest in project to be executed by SIPL-Agreement for sale-Project was not completed-whole profit cannot be taxed in the first year of execution of MOU-Matter remanded. [S. 145]

S. 2(14) : Capital asset-Rights or interest in a property-Period of holding is to be reckoned from date of first agreement, while calculating capital gains. [S. 2(42A), 2(42B), 45]