S. 14A : Disallowance of expenditure-Exempt income-Disallowance is restricted to extent of considering only those investments which yielded exempt income-Notional interest-Matter remanded for verification. [S. 4, R. 8D]

S. 14A : Disallowance of expenditure-Exempt income-Dividend from his personal investments-Deletion of addition is justified. [R. 8D]

S. 12AB : Procedure for fresh registration-Condition for granting registration-Granting registration for three years is held to be not valid-Direction issued for grant of registration for five years-Matter remanded. [S. 12A(1)(ac)(i), 12AB(1)(c) Form No. 10AC]

S. 11 : Property held for charitable purposes-Granting of tenancy to a company in which the trustees are interested-Premium charged-No violation of section 13((3)-Denial of exemption is not justified. [S. 12A, 13(3)]

S. 11 : Property held for charitable purposes-Search and seizure-Addition on protective basis-No incriminating material was found-More than 85 per cent of receipts of trust were applied for objects of trust-Denial of exemption is not valid. [S. 12A, 13, 132, 153C]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Pharmaceutical company-Clinical trials services-Payment to Mexico-Absence of ‘make available’ clause-Liable to deduct tax at source-DTAA-India-Mexico. [S. 9(1)(viib),195, Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Pharmaceutical company-Clinical trials services-Not liable to deduct tax at source-DTAA-India-USA-Canada. [S. 9(1)(vii), 195, Art. 12]

S. 9(1)(vii) : Income deemed to accrue or arise in India-Fees for technical services-Royalty-Commission for providing customer and support sales services-Export commission/sales commission and could not be treated as FTS-DTAA-India-Germany. [S. 9(1)(vi), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Sale of software products to its Indian clients-Cloud based services-Subscription fees-Not be taxable as royalty-DTAA-India-USA. [S. 9(1)(vii), Art. 12]

S. 9(1)(vi) : Income deemed to accrue or arise in India-Royalty-Fees for technical services-Sale of advertisement space on a website-No PE of foreign enterprises-Income neither royalty nor FTS-Online advertisement is now covered under Equalization Levy-DTAA-India-Ireland. [S. 9(1)(vii), Art. 12, Copyright Act, 1957, 14(a), 14(b), 30]