S. 11 : Property held for charitable purposes-Composite objects-Kalyan Mandapam on commercial lines for fees and cess like any other persons carrying business-Receipts from the marriage hall related activities are more than the specified limit as per proviso to S 2(15)-Rejection of exemption is justified-Printing a diary of trustees and their family members does not per se amount to diversion of trust funds for the benefit of trustees-Amounts spent for the Diwali get-together of the trustees in the course of carrying on activities of the trust cannot be considered as diversion of trust funds for the benefit of trustees-No violation under section 13(1)(c)-Depreciation-Commercial principle-Corpus donations-Exemption denied-Includable in total income-Expenditure-Expenditure is to be allowed for earning of income including its activities as deduction-House property for the benefit of the members of one family-Not allowable as deduction. [S. 2(15), 13(1)(c), 22, 24, 37(1), 133A]

S. 11 : Property held for charitable purposes-Corpus donation-Foreign donation-Project is struck on account of stay order of High Court-Amount utilised for repayment of bank loan-Exemption is allowable.[S.11 (1)(d))]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Interior design services-Payments received by the assessee from RCITP are fees for technical services falling under cl. (4) of art. 12 of the DTAA-DTAA-India-Singapore [S.90, 144C(5), 144(13), Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-User of software-Payment received cannot be taxable as fees for technical services or royalty-DTAA-India-Netherland [S. 9(1)(vi), 90, Art. 12(5)]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-None of the employees came to India for the purpose of either development or sale of or any activity related to development and sale of RPA software platform-No permanent establishment-No income attributable on sale of software licence-Additional ground-Rejected-DTAA-India-USA. [Art. 5, 12]

S. 271D : Penalty-Takes or accepts any loan or deposit-Sale of immoveable property-Stock in trade-Sale deed registered-No deliberate defiance of law-Penalty is deleted. [S.269SS]

S. 271AAB : Penalty-Search initiated on or after Ist day of July 2012-Cash payment-Recorded in balance sheet-Cannot be held to be undisclosed-Additional ground-Legal issue-Matter remanded to the CIT(A). [S. 270A,274, ITAT R. 27]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Additional depreciation-Revision order is quashed.[S. 32, 115JB, 147, 148]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Conversion firm to limited liability partnership-Firm dissolving on date of conversion-Income earned recorded in hands of Limited Liability Partnership-Tax deducted at source appearing in Firm’s name only allowed to firm and not limited liability partnership-No double grant of credit-Revision is not valid. [S. 142(1) 143(2)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Income from other sources-Interest-Debentures redeemed after nine years-Conversion of debentures into equity shares-Entire interest deemed to be received by debenture holder upon conversion of debentures into equity shares in year of conversion–Assessing Officer accepted the return-Revision is justified.[S. 2(24)(iv),47(x),49(2A),56,143(1)]