S. 12AA : Procedure for registration –Trust or institution- Order of Tribunal directing to grant registration is up held – If objects later found not genuine authority has option to cancel registration.[ S.2(15) 11, 12, 12A, Trust Act 1882 , Registration Act 1908 ]

S. 12A : Registration –Trust or institution- Statutory body for urban development under control of State Government is charitable institution entitled to registration. [ S.2(15),11 Rule 17A ]

S. 11 : Property held for charitable purposes – Depreciation – Allowable as deduction [ S.32 ]

S. 11 : Property held for charitable purposes – First proviso- Event of Garba organised to raise money — Amount earned entitled to exemption [ S.2(15), 12 ]

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Non -resident – Goods for export -Amount received as demurrage charges from seller in India — Held to be not taxable [ S.5 (2)(b), 40(a)(i), 172 ]

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S. 9(1((i) : Income deemed to accrue or arise in India – Business connection – Fees for professional or technical services – Deduction at source Amount paid to surveyors to settle the amount on cost to cost basis – No permanent Establishment in India – Not liable to deduct tax at source -DTAA- India -UK .[ S, 9(1)(vii), 90 194J ]

S. 264 :Commissioner – Revision of other orders – Application for refund — Delay in filing application not explained – Dismissal of revision application is held to be valid . [ S.119 (2)(b) Art , 226 ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue –Export business- Every loss of revenue as a consequence often order of the Assessing Officer cannot be treated as prejudicial to the interests of the Revenue- Revision is held to be not valid . [ S.80HHC ]

S. 263 : Commissioner – Revision of orders prejudicial to revenue – Amalgamation – Accumulated Loss and unabsorbed depreciation – Both conditions to be satisfied concurrently- Sick Industrial Companies (Special Provisions) Act, 1985, Act override those of the 1961 Act- Additional depreciation – Revision is held to be not valid .[ [S.72(2) 72A , Sick Industrial Companies (Special Provisions) Act, 1985, S. 18 32(2) ]

S. 254(2): Appellate Tribunal-Rectification of mistake apparent from the record – Duty of Tribunal to decide on merits – Appeal dismissed ex- parte for non prosecution- Granted liberty for recall of order – Application for recalling the order rejected on ground of limitation – Date of communication or knowledge, actual or constructive, of the orders sought to be rectified or amended under S. 254(2) of the Act becomes critical and determinative for the commencement of the period of limitation- Rejection of rectification is held to be not valid . [ S.254(1) ,Appellate Tribunal) Rules, 1963, R. 24 , 35 ]