S. 11 : Property held for charitable purposes-Audit report-Filing audit report in Form No. 10B is procedural in nature-For not filing audit report along with return, exemption cannot be denied-Matter is remanded to the file of CIT(A). [S. 12A, Form No.10B]

S. 10 (23C) : Educational institution-Two separate educational institutions-Gross receipts of each of educational institutions had to be separately considered for purpose of allowing claim of exemption. [S.10(23C))(iiiad)]

S. 10(1) : Agricultural income-Books of account-Agriculturist-No requirement to maintain books of account under section 44AA for agriculturists to claim exemption under section 10(1). [S.44AA]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-commercial information is transferred to end user-Not taxable as fee for included services-Installation and integration services-Not taxable as fees for technical services-DTAA-India-USA[Art. 12(4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Network fees from its Indian AE-Neither royalty nor fees for technical services-Not taxable in India-DTAA-India-Netherlands.[S. 4,9(1)(vi), Art.7, 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of online advertisement space to GIPL, India and to direct advertisers-Payment received from GIPL is not in nature of royalty or FTS-Not liable to tax in India-DTAA-India-Ireland.[S.9(1)(vii), Art. 12]

S. 9(1)(i) : Income deemed to accrue or arise in India-Business connection-Limited Liability Company (LLC)-Resident of USA State by virtue of US Income-tax Law-Qualified as a person under Article 4 of Indo-US Tax Treaty-Eligible for treaty benefit-Liable to tax at 15 % and not 25%-DTAA-India-USA [S.90, Art.4, 12]

S. 6(1) : Residence in India-Individual-Indian citizen-Stayed in India more than 183 days-Income derived in USA is chargeable to tax in India-DTAA-India-USA [S. 5, 9(1)(i),Art. 4(2)(a)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Excess provision of Corporate Social Responsibility expenses of earlier years should have been first written back to profit and loss account and not in Balance-Sheet-No discussion in the assessment order-Revision is justified. [S. 143(3)]

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Business expenditure-Four projects-Apportionment of expenditure to projects-Order of CIT is affirmed-The Principal Commissioner is required to provide reasonable opportunities of being heard to the assessee before deciding the case on the merits. [S.37(1)]