S. 11 : Property held for charitable purposes-Development of areas and infrastructural activities-Autonomous body established by Government of Gujarat-Matter is set aside to file of Assessing Officer to consider same in accordance with law as enumerated by Supreme Court in case of Asstt. CIT (E) v. Ahmedabad Urban Development Authority (2022) 291 Taxman 11/ 449 ITR 1 (SC).[S. 2(15) 12AA]

S. 11 : Property held for charitable purposes-Return was filed within time allowed under section 139(4)-Assessing Officer is directed to allow assessee’s claim of exemption. [S.12A, 139(1), 139(4), Form No.10B]

S. 11 : Property held for charitable purposes-Delay in filing Form No. 10-Matter remanded to the file of Assessing Officer-Assessee is directed to file exemption application before CIT(E). [S.11(2), Form No.10]

S. 11 : Property held for charitable purposes-Audit report Form 10B-Delay of 31 days-Pending before CIT(E)-Matter is remanded.[S. 12A(1)(b), Form 10B]

S. 11 : Property held for charitable purposes-Advancement of general public utility–Sponsorship agreements with few Indian business groups-Neither sponsor nor assessee could be attributed any profit motive from outcome of these sponsorship agreements-Eligible for exemption.[S. 2(15) 12]

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]