S. 10 (23C): Educational institution-Donations-not wholly or substantially financed by Government of India-Matter remanded to the file of CIT(A) for reconsideration. [S. 10(23C)(iiiab)]

S. 10(2A) : Share income of partner- No distributable profits-Partnership firm had earned profit-Partner is eligible to claim exemption.

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Business profits-Services rendered outside India-Cloud, colocation and network services, mainframe services, disaster/data recovery services-Infrastructure services to a US based company in US-Not taxable in India-DTAA-India-USA [Art. 12]

S. 9(1)(vii):Income deemed to accrue or arise in India-Royalty-Fees for technical services-Computer software-Use of standardized software through EULA agreements which were non-exclusive and non-transferable-Payment is not in nature of royalty-Not taxable in India-DTAA-India-USA. [S.9(1)(vi), Art. 12(4)(b)]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Providing consulting engineering services to an Indian entity-Contract specific-Make available-Not taxable as fees for technical services-DTAA-India-UK [Art. 13]

S. 9(1)(vii):Income deemed to accrue or arise in India-Fees for technical services-Use of equipments-Cannot be treated as royalty or fees for technical services-DTAA-India-Singapore [S. 9(1)(vi), Art. 12(4)(a)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Vessel hire charges-Royalty-Fees for technical services-Charter contract for transporting coal from one port to another through its ship-Not royalty-Rightly offered to tax under section 44B of the Act-DTAA-India-UAE [S. 9(1)(vii) 44B, Art. 13]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Permitting right to use of brand name/trademark-Taxable as royalties-DTAA-India-Turkey. [S. 2(47)Art. 12(3), 13(6)]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Computer software-Royalty-Income from sale of software to its distributor in India-Not in the nature of royalty-Not taxable in India-DTAA-India-Ireland.[S. 9(1)(vii), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of computer software products-Not royalty-DTAA-India-USA [Art. 12(3)]